1

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) 

# FOR PAPERWORK REDUCT ION ACT

SUBMISSION **Mandatory Civil Rights Data Collection**

**May 2015** 

# SUPPORTING STATEMENT , PART A :

JUSTIFICATION ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) The Civil Rights Data Collection (CRDC) is a longstanding and critical aspect of the overall enforcement and monitoring strategy used by the Department of Education ’s (ED) Office for Civil Rights (OCR) to ensure that recip ients of ED ’s federal financial assistance do not discriminate on the basis of race, color, national origin, sex, and disability . OCR relies on CRDC data as it investigates complaints alleging discrimination, determines whether the federal civil rights laws it enforces have been violated, initiates proactive compliance reviews to focus on particularl y acute or nationwide civil rights compliance problems, and provides policy guidance and technical assistance to educational institutions, parents, students, and others. The Department of Education (the Department) has collected CRDC data on school characteristics, programs, services, and student outcomes on a biennial basis since 1968. For many years, the collection operated as the Elementary and Secondary

Sch ool Civil Rights Compliance Report ( approved by OMB as control # 1870 - 0500 ) . Recent administratio ns of the CRDC

—2004, 2006, 2009

– 10 , and 2011

– 12

— were conducted primaril y on - line through a survey tool in partnership with EDFacts . As such, these four data collections were cleared as part of the EDFacts information collection package ( OMB control # 1875 - 0240 ) . For the 2013

– 14 CRDC and 2015

– 16 CRDC, OCR submitt ed a separate clearance package and it was cleared under OMB control # 1870 - 0504 . This clearance package included data elements that OCR propos ed as m andatory for the 2013

– 14 CRDC , as well as data elements proposed as optional for the 2013

– 14 CRDC and mandatory for the 2015

– 16 CRDC . The clearance was issued in February

2014 and expires in February 2016. Because the collection of the data for the 2015

– 16 CRDC will extend into 2017, this additional clearance is needed even though the2

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) p ackage is not materially different than the 2015

– 16 CRDC a pp roved in February

2014. Indeed, as explained in more det ail on page s 3 - 4 , OCR proposes only three material changes: (1) drop the “students transferred to a regular school for disciplinary reasons” data element ( the “students transferred to an alternative school ” data element would remain); (2) add new “child c ount for 2 - ye ar - olds served in LEA preschool” data element ; and (3) expand high school equivalency exam preparation program student participation and credentials data elements to include state authorized high school equivalency exam preparation programs in addition to the General Educational Development (GED) test preparation programs . **1. Explain the circumstances that make the collection of information necessary.**  **Identify any legal or administrative requirements that necessitate the collection. Attach**  **a hard**  **copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information**  **, or**  **you may provide a valid**  **URL link or paste the applicable section**  **. Please limit pasted text to no longer than 3**  **pages. Specify**  **the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change)**  **. If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed**  **sections, if applicable.** Sect ion 203(c)(1) of the 1979 Department of Education Organization Act convey s to the Assistant Secretary

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

General of the United States, OCR shares in the enforcement of Title II of the Americans with Disabilities Act of 1990, which prohibits discrimination based on disability . Any data collection that OCR has determined to be necessary to ascertain or ensure compliance with these laws is mandatory . OCR also works with ED offices to help them e ffectively carry out programs of Federal financial assistance that the Secretary of Education is responsible for administering. See generally , Sections 201, 202(g), 411(a), and 412 of the Department of Education Organization Act (20 U.S.C. §§ 3411, 3412(g ), 3471(a), 3 472, www.law.cornell.edu/uscode/text/20/3411 , www.law.cornell.edu/uscode/text/20/3412 , www.law.cornell.edu/uscode/text/20/3471 , and3

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) www.law.cornell.edu/uscode/text/20/3472 , respectively). OCR works with ED ’s Office of Elementary

and Secondary Education, which is responsible for administering the Elementary and Secondary

Education Act of 1965 (ESEA). Section 9533 of the ESEA (20 U.S.C. § 7913 , www.law.cornell.edu/uscode/text/20/7913 ) prohibits discrimination in the administration of the ESEA in violation of the Fifth or Fourteenth Amendments to the Constitution. In addition, Section 9534 of the ESEA (20 U.S.C. § 7914 , www.law.cornell.edu/uscode/text/20/7914 ) prohibits discrimination in funded programs on the basis of race, color, religion, sex (except as otherwise permitted under Title IX), national origin, or disability . Thus, in addition to OCR's authority described ab ove, the ESEA provides authority for ED to mandate that local educational agencies (LEAs) respond to this data collection. As with previous CRDC collections, the purpose of the 2015

– 16 CRDC is to obtain vital data related to the civil rights laws’ requirement that public LEAs and elementary and secondary schools provide equal educational opportunity . In p rep aring the original proposal for the 2013

– 14 CRDC and 2015

– 16 CRDC, OCR extensively anal yz ed the uses of every data element collected for 2011

– 12 , and sought advice from experts across ED to refine, improve, and where appropriate, add or remove data elements from the collection. The 2013

– 14 CRDC and 2015

– 16 CRDC redesign effort ensured that, while several new indicators were added to the collection, data elements also were removed where appropriate. OCR also made the CRDC data definitions and metrics consistent with other mandatory collections across ED wherever possible. The p ro p osed 2015

– 16 CRDC is nearly identical to the 2015

– 16 CRDC p reviously a pp roved by OMB in February

2014 (OMB control #1870 - 0504) . OCR is proposing several minor changes and clarifications for the previously- approved 2015

– 16 CRDC based on comments received and questions raised b y LEAs during the administration of the 2013

– 14 CRDC. In particular , OCR proposes the following :  drop the “ students transferred to a regular school for disciplinary reasons” data element from the collection ( the “ students transferred to an alternative school ” data element would remain in the collection) [see Attachment A - 2, pages 35 and 36 (Data Groups 922 and 923); also see Attachment A - 3, page 17 (Data Category : Discipline Method) ] ;  add new child count data element for c hildren who were two - years old on the child count date, but who were served in a local educational agency ( LEA ) preschool program for three - through five - ye ar - olds [see Attachment A - 2, page 70 (Data Group 957); also see Attachment A - 3, page 7 (Data Category: Age (Preschool)];  expand high school equivalency exam preparation program student participation and credentials data elements to include GED test preparation programs, High School Equivalency

Test (HiSet) preparation programs, Test Assessing Secondary C ompletion (TASC) preparation programs, and an y other state - authorized high school equivalency exam preparation programs [see Attachment A - 2, pages 46 and 47 (Data Groups 928 and 929); also see Attachment A - 4, page 17 (Directional Indicator 8) ] ;4

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable)

 alter the c hild count date for students served under the IDEA to October 1 of the school ye ar [see Attachment A - 2, page 109 (Data Group 180) ] ; and  modify the corporal p unishment indicator from whether a school uses corporal punishment to whether a school has an y students who receive corporal punishment [see Attachment A - 4, page 10 (Directional Indicator 4) ] . In all other res p ects, the proposed 2015

– 16 CRDC is identical to the 2015

– 16 CRDC that was approved in February

2014. The information in the n ext few paragraphs summarizes some general areas of information collected in the CRDC . For a more detailed list of what is proposed for the 2015

– 16 CRDC , see Appendix 1 to this Supporting Statement A. **School and District Characteristics** The CRDC will continue to cover such topics as the number of magnet and alternative schools, and districts operating under desegregation orders or plans, and student membership disaggregated b y race, ethnicity , sex, disability , and English learner status . The p roposed changes provide greater context to deepen OCR’s understanding of the schools and districts in which students receive their education. **Discipline** The results of the 2009

– 10 CRDC made public long - hidden data about indicators of school culture, including: numbers of students, broken down by demographic characteristics, who were suspended once and multiple times, expelled, and arrested in school; and new information about the use of restraint and seclusion in the classroom. The CRDC provide s add itional information about the amount of time students are suspended; this reflects the findings of OCR enforcement actions and other reports that have shown that disproportionality in discipline extends beyond the ty pe of punishment (in - or out - of - school s uspensions) to length of time out of class. **Harassment and B**  **ullying** Safe environments are critical to learning. T he 2009

– 10 CRDC was the first CRDC to provide a lens on school climate and the bullying and harassment that students too often endure on the basis of race, sex, and disability . In 2013

– 14 , OCR added sexual orientation and religion to ty pes of allegations of harassment that need to be counted, but the CRDC does not extend the reporting requirements about demographic data of the alleged complainant or harasser. (Note that the CRDC does not authorize schools to inquire about the sexual orientation or religion of students. Inclassifying the allegations of harassment or bullying, respondents are directed to look to the likely

motives of the alleged harasser/bully , and not the actual status of the alleged victim. See more information in response to question 11.)5

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **Early Childhood Education** The CRDC continues to cover such topics as children’s access to and participation in LEA operated earl y childhood education programs to learn more about how programs serve the yo ungest children. **Pathways to College and Career** The CRDC continues to cover topics such as students’ participation in Algebra and other college - preparatory

subjects, grade - level r etention, and access to Advanced Placement (AP) courses. CRDC also measures which schools have high and low chronic absenteeism rates. Chronic absenteeism can be a sign of serious school climate issues that are driving children out of school. It is also a warning sign of serious problems in the future for the child (e.g., dropping out). **School finance (funded with state and local funds)** Since 2009, the CRDC has been a source of information for exploring resource equity among schools within a district. T he CRDC provide s data on total personnel expenditures between schools for teachers and instructional aides, administrators, and those who provide critical support services for students and instruction. **Teachers (funded with federal, state, and/or local funds)**  Since 2009, the CRDC has been a resource for data on the number of first - and second - ye ar teachers in schools, the number of high school counselors in schools, and teacher absenteeism. The CRDC also asks for data about school support and security st affing data for every school and critical data elements taken from the NCES Schools and Staffing Survey . These data deepen our understanding of how to make schools and communities safer and allow OCR to compare resources available to schools of different p opulations. **2. Indicate how, by whom, and for what purpose the information is to be used. Except**  **for a new collection, indicate the actual use the agency has made of the information received from the current collection.**  Since 1968, the CRDC (and its predecessor surveys) have served as the cornerstone for federal enforcement of children’s civil rights in public schools. OCR relies on CRDC data as it investigates complaints alleging discrimination, determines whether the f ederal civil rights laws it enforces have been violated, initiates proactive compliance reviews to focus on particularl y acute or nationwide civil rights compliance problems, and provides policy guidance and technical assistance to educational institutions , parents, students, and others. In 2009, OCR extensively redesigned the CRDC. It sought input from a wide range of experts within the Department and throughout federal government, and from stakeholders from state and local education agencies and the bro ader education community , through meetings and two public comment periods. Sources of advice and expertise included the Education Information6

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Management Advisory

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

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

process. The resulting 2009

– 10 CRDC was more detailed, providing new data on college and career - readiness, discipline, teacher equity , retention, access to pre - K programs, bullying and harassment, and school - level expenditures, and disaggregating data by race, ethnicity , sex, disability , and English learner status. The transformed 2009

– 10 CRDC was heralded as a first - of - its - kind opportunity

gap data tool that is allowing citizens and schools nationwide to identify educational equity- related problems and their solutions. For OCR staff across the country , as they launch investigations, the CRDC is used to prepopulate their data requests so that recipients do not have to make duplicate reports and submissions. This expedites investigations and reduces the reporting burdens. The 2011

– 12 CRDC built on these efforts by adding more data checks ( to ensure the data’s integrity) , and by

combining the fall snapshot data and spring outcome data collection periods into a single collection period ( to minimize the burden to respondents ) . For the 2013

– 14 CRDC, additional improvements to the data submission system were made to enhance the user interface and experience. Several data entry and s ys tems tools were introduced to make the process intuitive and reduce the burden for the user. The ability to res et passwords and add additional users was refined, as well as the skip logic, downloadable error reports and data summaries. The CRDC’s utility

reaches far beyond OCR to the entire Department, to other Federal agencies and to researchers and policy makers a cross the nation. CRDC data have also been used b y other Department offices for purposes such as monitoring compliance with requirements for federal professional development funding, monitoring states under ESEA flexibility waivers, defining program requir ements on discipline disparities in the Race to the Top district competition , and evaluating the Office of English Language Acquisition’s (OELA) programs and activities. Individual offices also rely on CRDC data to analyze issues and prepare reports on to pics such as achievement gaps. State and federal agencies, policy makers, researchers, and many others outside of the Department also use the CRDC data. (Data are available to the public via the Web in privacyprotected format.) For each of these constit uencies, the CRDC is an invaluable source of information about access to educational opportunities in our nation’s public schools. Researchers, advocacy

organizations, and news media have used CRDC data to identify possible civil rights concerns in our nation’s schools and to find models of success. State legislatures and state boards of education have relied on CRDC data in crafting and revising educational policies. And for LEAs and schools across the country , the CRDC data is a critical tool for self - anal ys is and a mechanism for highlighting and correcting areas of educational concern.7

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **3. Describe whether, and to what extent, the collection of information involves the use**  **of automated, electronic, mechanical, or other technological collection techniques or**  **forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe any**  **consideration given to using technology to reduce burden.** Like recent collection s, the primary collection instrument for the 2015

– 16 CRDC will be a Web based s ys tem; users will either upload data files and/or enter the data in response to questions displayed on the screen; and the data will be transmitted directly into a database. To reduce burden, the Department will utilize a user - friendly interactive tool that ensures schools and LEAs only have to answer applicable questions. Guiding questions facilitate this approach and may precede data group tables. For example, if a user indi cates the school serves only elementary students, the questions about high schools will not be presented. Similarly , a high school will be asked if the school provided Advanced Placement (AP) courses. If the user answers “No,” then the series of tables a

bout AP will be skipped; if the user answers “Yes,” then the tables about AP will be presented. Flat file submissions, such as Excel files, are allowed for districts that have the capacity to create them; and paper submissions are allowed for LEAs with no Internet connectivity or limited Web access. States that wish to submit data on behalf of their LEAs are allowed to do so, as they have been in the past. Prior to the 2011

– 12 CRDC , LEAs had to choose to submit all their data either by flat file submissi on (FFS) or through the Web - based s ys tem. For the 2011

– 12 CRDC, OCR implemented improvements to the web collection tool to allow LEAs the flexibility to use both methods of submitting their data to the CRDC. As a result, the percentage of LEAs using FFS increased significantl y, from 6% in 2009 to 26% in 2011. The flexibility

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

or complete the remaining sections of the CRDC. This option will continue to be availa b le in the 2015

– 16 collection. Through computer control of the d ata collection process and the monitoring of responses, the web - based s ys tem offers the capacity for substantial improvements in data quality and data collection efficiency

over a survey

conducted using paper and pencil. Incidents of missing and inconsist ent data are greatly reduced since questionnaire skip patterns are automatically controlled. Moreover, invalid entries, contradictory entries, or entries inconsistent with available data on the school or LEA are questioned b y the sy stem and must be resolv ed or confirmed b y the respondent during the self - directed Web instrument data collection.8

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **4. Describe ef** 

**forts to identify duplication. Show specifically why any similar**  **information already available cannot be used or modified for use for the purposes descri**  **bed in Question**  **2 above.**  The CRDC is the unique source of data for the vast majority of data elements collected. Starting with the 2009

– 10 CRDC, OCR leveraged data submitted to the Department by state departments of education to reduce the burden on LEAs. In addition, in planning the 2009

– 10 CRDC, OCR carefully examined all data groups already collected by

EDFacts and dropped several tables previously

in the CRDC because the data are available through the state - based portion of EDFacts , the EDEN Submission System (ESS). OCR continues to use this approach for the CRDC. For the 2013

– 14 CRDC and 2015

– 16 CRDC, OCR met with program offices across the Department to eliminate any duplication of data items and, where possible, ensure the CRDC uses definitions consistent with those used by other program offices. For example, OCR worked closely with the National Center on Educational Statistics (NC ES) to align the definitions used for the collection of school - level expenditures with the definitions used by NCES and the Bureau of the Census in the collection of district - level expenditures. In order to consolidate and centralize preschool - 12 data coll ections, definitions need to be standardized. If the same term has multiple definitions, the reporting burden on LEAs and SEAs increases significantl y. Therefore, the same definitions of terms are used whenever possible. To coordinate the definitions use d and identify possible duplication of data elements, OCR met with key staff throughout the Department and convened a two - day technical working group, including participants from NCES, the Office of Planning, Evaluation and Policy Development, the Office o f English Language Acquisition, the Office of Special Education Programs, and the Correctional Re - Entry

Group, to review the proposed 2013

– 14 CRDC and 2015

– 16 CRDC. This cross - program office coordination provided an opportunity for experts in content areas and survey design to raise potential areas of overlap . OCR has also been working with the Department of Justice’s Office of Juvenile Justice, Delinquency and Prevention to improve the coordination of information about the educational programs and opportunities that are available to youths in justice facilities. **5. If the collection of information impacts small businesses or other small entities,**  **describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be on**  **e that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not**  **** **for -**  **profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small governme**  **nt jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less**  **than 50,000.** With the exception of two state educational agencies (SEAs), e ach l ocal e ducation a genc y (LEA) that is inc luded submits an LEA summary survey and a survey

about each school in the LEA (one SEA provided all the data on behalf of its LEAs and another SEA provided some data on9

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) behalf of its LEAs during this time) . Generall y, the collection has included a sample of about 6,000 - 7,000 LEAs . T he 1976, 2000, 2011

– 12 , and 2013

– 14 collections were universal collections from all LEAs. The CRDC is a mandatory data collection. T he CRDC allows small districts with limited or no Web access to submit via a paper form. For the 2011

– 12 CRDC, 0.1% (16 out of nearl y 17,000) of LEAs submitted the CRDC through a paper form. Additionally , smaller LEAs often face additional challenges with the timing of the CRDC collection. At the close of the school ye ar, small and rural LEAs “roll over” their data sy stems, effectivel y closing out one school year and beginning the next. The end of year “roll over” can make accessing data from the prior school year challenging. With advice from the CRDC workgroup, which includes representatives from geographicall y diverse LEAs and SEAs, OCR created a set of pre - collection tools to allow smaller LEAs to collect and store their CRDC data in a format that could be easil y uploaded into the CRDC submission system. With these tools, smaller LEAs could store their CRDC data in ready- to - use flat files once the survey submission website opened in the fall of the next school year. These pre - collection tools were widely used and OCR received man y positive comments regarding their ease of use. As a result, OCR plans to continue to provide these tools for the 2015

– 16 CRDC. **6. Describe the consequences to Federal program or policy activities if the collection is**  **not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducin**  **g burden.** Education in this nation is on an annual cycle where success and failure are measured and reported annuall y and civil rights complaints must be investigated and resolved on an ongoing basis. The most recent CRDC contained data from the fall and spring of school year 201 3

– 14 . It is critical that more recent information be available so that the Department can carry out its mandate to ensure civil rights under the applicable laws. Further, OCR enforcement offices rel y on data in the CRDC to prepop ulate data requests to districts and schools when conducting investigations and compliance reviews. It is important that OCR have recent data to conduct these investigations.10

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **7. Explain any special circumstances that would cause an information collection to**  **be conducted in a manner:**   **requiring respondents to report information to the agency more often than quarterly;**   **requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;**   **requiring respondents to submit more than an original and two copies of any**  **document;**  **requiring respondents to retain records, other than health, medical, government contract, grant**  **- in**  **- aid, or tax records for more than three years;**   **in connection with a statistical s urvey, that is not designed to produce valid and**  **reliable results than can be generalized to the universe of study;**  **requiring the use of a statistical data classification that has not been reviewed and approved by OMB;**   **that includes a pledge of confidentia lity that is not supported by authority**  **established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessarily**  **impedes sharing of data with other agencies for compatib le confidential use; or**   **requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures**  **to protect the information’s confidentiality to the extent permitted by law.**  This information collection activity does not have special circumstances that would include any of the requirements listed above. **8. As**  **applicable, state that the Department has published the 60 and 30 Federal**  **Register notices as required by 5 CFR 1320.**  **8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments**  **received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments receiv**  **ed on cost and hour burden.**  Describe efforts to consult with persons outside the agency to obtain their views on the availability

of data, frequency

of collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years – even if the collection of informat ion activity

is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained. The Department will provide the public an opportunity to comment through both 60 - day and 30 - day notices.11

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Additionally , d

uring the two - day

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

staff throughout the Department who offered their recommendations on improvements to data items. Following the technical working group review of the CRDC data elements, the full list of proposed new data elements and data elements OCR proposed to no longer collect was reviewed and approved b y the Department’s Policy Committee, which sought to ensure the collection of these data elements was necessary , permitted and non - duplicative. On a semi - annual basis, OCR convenes a workgroup of representatives from geographicall y diverse LEAs and SEAs to provide guidance and advice on way s to improve the CRDC. The CRDC workgroup play s a vital role in understanding the availability of data, within either state or local data s ys tems, and the burden of reporting new or continuing data items. **9. Explain any decision to provide any payment or gift to respondents, other than**  **remuneration of co ntractors or grantees**  **with meaningful justification .**  There is no current remuneration for any school district or school. **10. Describe any assurance of confidentiality provided to respondents and the basis for**  **the assurance in statute, regulation, or agency p olicy. If personally identifiable**  **information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the**  **date a Privacy Impact Assessment was completed as indic**  **ated on the IC Data Form .**  **A confidentiality statement with a legal citation that authorizes the pledge**  **of confidentiality**  **should be provided. Requests for this information are in accordance**  **with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A**  **- 108** 

**– Privacy Act Implementation**  **– Guidelines and Responsibilities, OMB Circular A**  **** **130 Appendix I –**  **Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M**  **- 03**  **- 22**  **– OMB Guidance for Implementing the Privacy**  **Provisions of the E**  **- Government Act of 2002, OMB M**  **- 06**  **- 15**  **– Safeguarding**  **Personally Identifiable Information, OM:6 -**  **104 –**  **Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)**  **. If the collection is**  **subject to the Privacy Act, the Priva cy Act statement is deemed sufficient with**  **respect to confidentiality. If there is no expectation of confidentiality, simply state that the Department make**  **s no pledge about the confidentially of the data.**  There has been no assurance of confidentiality prov ided to the respondents beyond the agreement to protect individual student information under the Federal Educational Rights and Privacy Act. The CRDC does not collect any personally

identifiable information (PII). Confidentiality

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

data in rows or columns where a single cell is below a certain threshold of size. OCR will continue to review the submitted data for any other security requirements.12

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **11. Provide additional justification for any questions of a sensitive natu**  **re, such as sexual behavior and attitudes, religious beliefs, and other matters that are**  **commonly considered private. The justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the**  **inform ation, the explanation to be given to persons from whom the information is**  **requested, and any steps to be taken to obtain their consent.** As noted above in response to question 1, OCR propose s to collect data about the number of allegations received b y a sc hool of bullying/harassment on the basis of religion and sexual orientation. In the last OMB a pp roval in February 2014 (OMB control #1870 - 0504) , the collection of this data was a pp roved as o p tional for the 2013

– 14 CRDC and mandatory for the 2015

– 16 CRDC. The questions are not intended or expected to elicit private information about students. The questions are intended to record, for an y reported harassment, the school’s understanding about the harasser’s perceived motivation. In classifying the allegations of harassment or bullying, respondents are directed to look to the likely motives of the alleged harasser/bully , and not the actual status of the alleged victim. Because the questions are not focused on students’ sexual behavior or attitudes or religious beliefs, OCR does not believe these questions are of a sensitive nature. OCR again proposes to collect only the number of allegations received b y a school of bullying and harassment on the basis of sexual orientation or religion. OCR is not proposing that schools collect data about students’ sexual orientation or religion. OCR is not proposing that schools collect counts of students who were harassed or disciplined for harassment on those bases. S chool districts will not be required to include perceived sexual orientation or religious affiliation of students as part of their administrative records. To assess whether even making an inquiry about the number of allegations of harassment received b y a school might cause invasions of privacy , during preparat ion for the 2013

– 14 CRDC and 2015

– 16 CRDC OMB clearance in 2013, OCR contacted SEAs in some of the 10 states that currently

collect such sexual orientation harassment data from their public school districts and none reported any student or parental complaints or known incidents of teachers invading student privacy

in an effort to fill out the state’s data reporting forms. OCR also contacted several school districts (of various sizes and urban/rural mix) in those states to determine whether these dat a reporting requirements had led to sexual - orientation notations on individual student records or had raised any complaints or concerns and none were reported.13

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **12. Provide estimates of the hour burden of the collection of information. The**  **statement should:**  **Indicate the number of respondents by affected public type (federal government, individuals or households, private sector**  **– businesses or other for**  **- profit, private**  **sector –**  **not -**  **for -**  **profit institutions, farms, state, local or tribal governments), frequency**  **of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden type: recordkeeping,**  **reporting or third party disclosure. All narr ative should be included in Question**  **12. Unless directed to do so, ag encies should not conduct special surveys to**  **obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden**  **on respondents is expected to vary widely because of differences in activity, size,**  **or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for**  **customary and usual business practices.**  **If this request for appro val covers more than one form, provide separate hour**  **burden estimates for each form and aggregate the hour burdens in the ROCIS**  **IC Burden Analysis Table. (The table should at**  **minimum include Respondent**  **types, IC activity, Respondent and Responses, Hours/R esponse, and Total**  **Hours)**  **Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate**  **categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be**  **included in Question**  **14.** For the CRDC , the respondent is the LEA; the LEA must complete one LEA - level survey plus one school - level survey

for each of its schools. For the 20 11

– 12 CRDC , the burden was estimated to be 1,282,492 hours across 16,785 LEA respondents and their approximately 96,523 schools with students in membership, based on an estimated 12.8 hours per school survey and 2.8 hours per LEA survey on average. For el ementary schools, the burden was estimated to be 8.1 hours per school survey since several of the data elements are onl y applicable to secondary schools. For secondary schools, the burden was estimated to be 14.9 hours per school survey . The 2013

– 14 CRD C mandatory survey content remain s about the same compared to the 2011

– 12 CRDC survey for Preschool - 12 schools. Approximately 17,620 LEAs will respond for themselves and their 101,849 schools to the request for data. This results in a total burden estimate of 1,342,818 hours. For elementary schools, the burden is estimated to be 8.3 hours per school survey

since s everal of the data elements are only applicable to secondary schools. For secondary schools, the burden is estimated to be 14.6 hours per school survey . By combining several data elements on Advanced Placement, the overall reporting burden for secondary schools decreases slightly from the 2011

– 12 CRDC to the 2013

– 14 CRDC . Since the number of schools per LEA varies so widely it should be noted that a district with only one school would,14

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) on the average, take 2.8 hours for the LEA survey and 12.7 hours for the school survey , for a total of 15.5 hours. An LEA with 10 schools would take 2.8 hours on the LEA survey and average 12.7 hours on each of the school survey s, for a total of 129.8 hours. The 2015

– 16 CRDC survey content will increase by

approximately

1 3 percent compared to the 2013

– 14 CRDC survey

for Preschool - 12 schools, based on a total burden estimate of 1,5 20,260 hours. For elementary

schools, the burden is estimated to be 9.3 hours per school survey since several of the data elements are onl y appli cable to secondary schools. For secondary schools, the burden is estimated to be 15. 9 hours per school survey . Since the number of schools per LEA varies so widel y, it should be noted that a district with only one school would, on the average, take 4.2 h ours for the LEA survey and 14. 2 hours for the school survey , for a total of 18.4 hours. An LE A with 10 schools would take 4.2 hours on the LEA survey and average 14. 2 hours on each of the school surveys , for a total of 146.2 hours. Respondents Hours/R esponse Total Hours Previous

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

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

– CRDC (2013) Schools: 101,849 LEAs: 17,620 Schools: 12.7 LEAs: 2.8 Schools: 1,293,482

LEAs: 49,336 Total: 1,342,818 New

– CRDC (2015) Schools: 101,849 LEAs: 17,620 Schools: 14. 2 LEAs: 4.2 Schools: 1,4 46,256

LEAs: 74,004 Total: 1,5 20,260 **New Burden (2011**  **to 2015**  **)** Schools: +1. 4 hrs/survey LEAs: +1.4hrs/survey Schools: 2 10,762 LEAs: 27,006 Total: 237,768 The total respondent cost for the 201 5

– 16 CRDC is estimated to be $ 68,411,700 ( 1,520,260 hours multiplied by

an average wage of $45 per hour). There is a wide range o f hourl y salaries associated with the professionals that will provide this data, but $45/hour is a reasonable average.15

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **13. Provide an estimate of the total annual cost burden to respondents or record**  **keepers resulting from the collection of information. (Do no t include the cost o**  **f any hour burden shown in Questions**  **12 and 14.)**  **The cost estimate should be split into two components: (a) a total capital and start**  **- up cost component (annualized over its expected useful life); and (b) a total**  **operation and maintenanc e and purchase of services component. The estimates**  **should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to**  **estimate major cost factors including system and technology acquisition,**  **expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start**  **- up costs include,**  **among other items, preparations for collecting information such as purc hasing**  **computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.**   **If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reas**  **ons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate.**  **In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60**  **- day pr**  **e -**  **OMB submission public comment process and use existing economic or regulatory impact analysis**  **associated with the rulemaking containing the information collection, as appropriate.**   **Generally, estimates should not include purchases of equipment or services , or**  **portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3)**  **for reasons other than to provide information or keep records for the government**  **or (4) as part of customary and usual business or private practices.**  **Also, these estimates should not include the hourly costs (i.e., the monetization of t**  **he hours) captured above in Question 12**  **. 14.**  **Total Annualized Capital/Startup Cost: Total Annual Costs (O&M):**  **Tot al Annualized Costs Requested:**  The collection of CRDC data for the foreseeable future will require no additional sy stems development efforts b y the local agencies.16

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **15. Provide estimates of annualized cost to the Federal government. Also, provide a**  **descripti on of the method used to estimate cost, which should include quantification**  **of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this**  **collection of inform ation. Agencies also may agg**  **regate cost estimates from Questions**  **12, 13, and 14 in a single table.** The estimated annual government cost for the next CRDC is $ 4.942 million . This estimate is based on contractual costs to develop a revised survey tool, provide technical support for all LEAs in the nation, and produce and anal yz e the resulting database of survey responses. **16. Explain the reasons for any program changes or adjustments. Generally,**  **adjustments in burden result from re -**  **estimating burden and/or f rom economic**  **phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from**  **a deliberate action that materially changes a collection of information an d generally**  **are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be**  **disaggregated by type of change (i.e., adjustment, program change due to new statute**  **, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without change) and**  **include totals for**  **changes in burden hours , responses**  **and cost s**  **(if applicable) .**  The 2015

– 16 CRDC survey content revisions are a result of program change due to agency discretion . Approximately 17,620 LEAs will respond for themselves and their 101,849 schools to the request for data. This results in a total burden estimate of 1,520,260 hours for SY 2 015

– 16 . The annual government cost is similar to the cost of previous survey s, the last of which was the 201 3

– 14 CRDC, conducted in 201 5 . **17. For collections of information whose results will be published, outline plans for**  **tabulation and publication. Address any complex analytical techniques that will be used.**  The Department presently makes CRDC results available on the Web with privacy prot ections in place. Additionall y, the Department makes available on the Web national and state projections based on the raw data. The Department makes data available through a website that display s a “summary

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

the public and OCR’s investigators and attorney s, OCR designed a new Web - based data reporting tool that allows users to tailor the school - level indicators and produce visuall y intuitive graphic displays of school - and district level tables, and made it available to the public in a privacy- protected format on OCR’s website,17

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) http://ocrdata.ed.gov . The new website i s also research - friendly . For example, users have enhanced ability

to search and query

the database for ty

pes of schools , as well as schools or districts meeting certain criteria. **18. Provide the time schedule for the entire project, including beginning and en**  **ding dates of the collection of information, completion of report, publication dates, and**  **other actions.** There are three distinct phases of the collection of CRDC data from LEAs :  Notification and verification of reporting status,  Collection of data b y LEAs , and  Survey

submission window. The first phase in the CRDC is to notify school districts of their obligation to report, designate a principal point of contact, and verify the reporting status of LEAs and schools. The result of this first phase is a full directory of LEAs and schools an d their CRDC reporting status. This phase will begin in Fall 2015 for the 2015

– 16 collection. During the second phase of the CRDC, LEAs gather and validate the require d data to be submitted to OCR. During this time, OCR provides frequent training opportunities for school districts to understand the data elements collected on the CRDC and the survey submission process. A support center is also available to school districts to call or email questions regarding the content of the data to be collected. OCR h as also provided pre - collection tools for school districts to gather and prepare flat files of the required data to prepare for the survey submission opening. T his second phase will take place between Fall 2015 and Summer 2016. During the third phase, the survey submission widow opens with email notification to all participating school districts. School districts are typically given a minimum of three months to submit their data to OCR. During the survey submission period, frequent communication occurs wi th participating school districts to offer technical assistance and, as the survey due date approaches, reminders are sent to school districts that have not yet certified their CRDC submission. W e anticipate this third phase will take place between Fall 2 016 and Winter 2017. Following the close of the survey submission window, OCR reviews the data to identify possible reporting anomalies and offer LEAs an opportunity to amend their CRDC submission as necessary . This process take s approximately three month s. Following the data quality review, OCR then works to post the data on its reporting website (ocrdata.ed.gov) to provide the public with easy access and visually

intuitive display s of the data.18

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) **19. If seeking approval to not display the expiration date**  **for OMB approval of the information collection, explain the reasons that display would be inappropriate.**  This collection will display the OMB approval date in all transmittal documents requesting the information from the state or local agencies and in any written discussion or representation of the collection. The OMB number will be properl y displayed on any Web form and paper form used by the Civil Rights Data Collection. **20. Explain each exception to the certification statement identified in the Certificatio**  **n of Paperwork Reduction Act.**  ED is requesting no exemptions from the Certification.19

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable)



# APPENDIX: LIST OF 2015

– 16 CRDC QUESTIONS **Items tha t OCR is p**  **roposing to change from the previously**  **- approved**  **OMB 2015**  **– 16**  **CRDC Information Collection in February 2014 are indicated by**  **underline or**  **strike through**  **.** School & District Characteristics Number of public schools (LEA) Grades offered (PS - 12) (PS refers to preschool and excludes birth - 2) Whether ungraded school has mainly elementary

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

onl y: Ty pe of facility

(pre - or post - adjudication/conviction or both) Number of day s that makeup the justice facility ’s regular school ye ar Total number of hours per week that educational p rogram is offered during regular school ye ar Number of students who participated in educational program for less than 15 calendar day s; 15 - 30 calendar day s; 31 - 90 calendar day s; 91 - 180 calendar day s; more than 180 calendar day s. Whether co - educational scho ol has one or more single - sex classes Number of single - sex academic classes (with males only ; with females only) in the following courses/subject areas: Algebra I, Geometry , and/or Algebra II Other mathematics Science English/reading/language arts Other academic subjects20

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Whether LEA has civil rights coordinators for discrimination against students on basis of sex, race, and disability

(and contact information) (LEA ) Whether LEA is covered by desegregation order or plan (LEA) Discipline Students (K - 12) who received one or more in - school suspension: Number of K - 12 students without disabilities who received one or more in - school suspension (disaggregated b y race, sex, LEP) Number of K - 12 students with disabilities who received one or more in - school suspens ion (disaggregated b y race, sex, disability- 504 onl y, LEP) Students who received one out - of - school suspension: Number of preschool students who received one out - of - school suspension (disaggregated b y race, sex, disability- IDEA, LEP) Number of K - 12 student s without disabilities who received one out - of - school suspension (disaggregated b y race, sex, LEP) Number of K - 12 students with disabilities who received one out - of - school suspension (disaggregated b y race, sex, disability- 504 onl y, LEP) Students who recei ved more than one out - of - school suspension: Number of preschool students who received more than one out - of - school suspension (disaggregated b y race, sex, disability- ID EA, LEP) Number of K - 12 students without disabilities who received more than one out - of - school suspension (disaggregated by race, sex, LEP) Number of K - 12 students with disabilities who received more than one out - of - school suspension (disaggregated by race, sex, disability- 504 only , LEP) Number of preschool students who were expelled (disa ggregated b y race, sex, disabilityID EA, LEP) Students (K - 12) who were expelled (with educational services; without educational services; because of zero - tolerance policies): Number of K - 12 students without disabilities who were expelled (with educational services; without educational services; because of zero - tolerance policies) (disaggregated by race, sex, LEP) Number of K - 12 students with disabilities who were expelled (with educational services; without educational services; because of zero - tolerance p olicies) (disaggregated by race, sex, disability- 504 onl y, LEP) Students (K - 12) who were removed for disciplinary reasons (to alternative school; to regular school ): Number of K - 12 students without disabilities who were removed for disciplinary reasons (to alternative school; to regular school ) (disaggregated by race, sex, LEP) Number of K - 12 students with disabilities who were removed for disciplinary reasons (to alternative school; to regular school ) (disaggregated by race, sex, disability- 504 only , LEP) Students (K - 12) who were referred to law enforcement agency or official: Number of K - 12 students without disabilities who were referred to law enforcement agency or official (disaggregated by race, sex, LEP)21

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Number of K - 12 students with disabilities who were referred to law enforcement agency or official (disaggregated by race, sex, disability- 504 only , LEP) Students (K - 12) who were arrested for school - related activity : Number of K - 12 students without disabilities who were arrested for school - related acti vity (disaggregated b y race, sex, LEP) Number of K - 12 students with disabilities who were arrested for school - related activity (disaggregated b y race, sex, disability- 504 onl y, LEP) Students who received corporal punishment: Number of preschool students (a ges 3 - 5) who received corporal punishment (disaggregated by race, sex, disability- IDEA, LEP) Number of K - 12 students without disabilities who received corporal punishment (disaggregated b y race, sex, LEP) Number of K - 12 students with disabilities who received corporal punishment (disaggregated by race, sex, disability- 504 only , LEP) Number of instances of corporal punishment that students (preschool through grade 12) received (disaggregated by students without disabilities, students with disabilities) Number of school days missed by students who received out - of - school suspensions (disaggregated b y students without disabilities, students with disabilities (IDEA), students with disabilities (504 only) Documented incidents that occurred at the school that would trigger discipline, including referrals to law enforcement and arrests: Number of incidents of robbery with a weapon Number of incidents of robbery with a firearm or explosive device Number of incidents of robbery without a weapon Number of incidents of phy sical attack or fight with a weapon Number of incidents of phy sical attack or fight with a firearm or explosive device Number of incidents of phy sical attack or fight without a weapon Number of incidents of threats of ph ys ical attack with a weapon Number of incidents of threats of ph ys ical attack with a firearm or explosive device Number of incidents of threats of ph ys ical attack without a weapon Number of incidents of rape or attempted rape Number of incidents of sexual battery (other than rape) Number of incidents of possession of a firearm or explosive device Whether an y of the school’s students, faculty, or staff died as a result of a homicide committed at the school Whether there has been at least one incident at the school that involved a shooting (regardless of whether an yone was hurt) Harassment and bullying Number of reported allegations of harassment or bullying of K - 12 students on the basis of: sex; race, color, or national origin; disability ; sexual orientation; religion Number of K - 12 students reported as harassed or bullied on the basis of: sex; race, color, or national origin; disability (disaggregated b y race, sex, disability- ID EA, disability- 504 onl y, LEP)22

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Number of K - 12 students disciplined for engaging in harassment or bull yi n g on the basis of: sex; race, color, or national origin; disability (disaggregated by

race, sex, disability- IDEA, disability- 504 only , LEP) Restraint and Seclusion Students (K - 12) subjected to mechanical restraint: Number of non - IDEA K - 12 students subjec ted to mechanical restraint (disaggregated b y race, sex, disability- 504 only , LEP) Number of K - 12 students with disabilities (IDEA) subjected to mechanical restraint (disaggregated b y race, sex, LEP) Students (K - 12) subjected to phy sical restraint: Number of non - IDEA K - 12 students subjected to phy sical restraint (disaggregated b y race, sex, disability- 504 onl y, LEP) Number of K - 12 students with disabilities (IDEA) subjected to phy sical restraint (disaggregated b y race, sex, LEP) Students (K - 12) subjected to seclusion: Number of non - IDEA K - 12 students subjected to seclusion (disaggregated by race, sex, disability- 504 only , LEP) Number of K - 12 students with disabilities (IDEA) subjected to seclusion (disaggregated by race, sex, LEP) Number of instances of mechanical restraint, ph ysical restraint, seclusion (disaggregated b y students without disabilities, students with disabilities - IDEA, students with disabilities - 504 only) Single Sex Interscholastic Athletics Whether the school has any students who participate in single - sex interscholastic athletics Number of single - sex interscholastic athletics high school sports (with males only ; with females only) Number of single - sex interscholastic athletics high school teams (with males only ; with females only) Number of student participants on single - sex interscholastic athletics high school sports teams (with males only ; with females only) Early Childhood Education Whether LEA provides early childhood program(s) for children birth - 2 (LEA) Whether LEA’s earl y childhood program(s) serve non - IDEA children birth - 2 (LEA) Preschool length offered (full - day , part - day) and cost (free, partial charge, full charge) (LEA ) Number of students served by L EA in preschool programs in LEA and non - LE A facilities (disaggregated b y age – 2, 3, 4, 5) (LEA) Whether preschool is provided to: all students, students with disabilities (IDEA), students in Title Ischools, students from lo w income families (LEA ) Whether preschool serves non - IDEA students age 3; age 4; age 5 (LEA) Number of students ages 3 - 5 enrolled in preschool (disaggregated by race, sex, disability- ID EA, LEP)23

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Whether the school’s preschool program serves non - IDEA students (disaggregated b y age -- 3, 4, 5) Whether LEA is required to provide full - day or part - day

kindergarten b y state statute or regulation (LEA ) Kindergarten length offered (full - day , part - day) and cost (free, partial charge, full charge) (LEA) Pathways to College and Career Whether the school has one or more gifted/talented programs Number of students enrolled in gifted & talented programs (disaggregated by race, sex, disability- IDEA, LEP) Whether students are enrolled in distance education courses (LEA) Number of students enrolled in distance education courses (disaggregated by race, sex, disability- IDEA, LEP) (LEA) Whether an y students participate in a dual enrollment/dual credit program Number of students enrolled in at least one dual enrollment/dual credit program (disaggregated b y race, sex, disability- ID EA, LEP) Whether the school has any students who participate in at least one credit recovery program that allows them to earn missed credit to graduate from high school Number of students absent 15 or more school days (disaggregated b y race, sex, disability- IDEA, disability- 504 only , LEP) Whether the school offers the International Baccalaureate Diploma Programme Number of students enrolled in the International Baccalaureate (IB) Diploma Programme ( disaggregated b y race, sex, disability- ID EA, LEP) Whether students are enrolled in one or more AP courses Number of different AP courses provided Whether students are allowed to self - select for participation in AP courses Number of students enrolled in at least one AP course (disaggregated b y race, sex, disabilityID EA, LEP) Number of students enrolled in at least one AP course in specific subject area (disaggregated by race, sex, disability , LEP) AP math of an y kind AP science of an y kind Other AP subjects of an y kind (including foreign language) Number of students who took one or more AP exams for one or more (which may include all) AP courses enrolled in (disaggregated b y race, sex, disability- IDEA, LEP) Number of students who were enrolled in on e or more AP courses but who did not take an y AP exams (disaggregated by race, sex, disability- IDEA, LEP) Number of students who passed one or more AP exams for one or more (which may include all) AP courses enrolled in (disaggregated b y race, sex, disabil ity- IDEA, LEP) Number of students who did not pass any AP exams for the one or more AP courses enrolled in (disaggregated b y race, sex, disability- IDEA, LEP) Number of classes in math and science (Algebra I, Geometry , Algebra II, Advanced Math, Calculus, B iology , Chemistry , Phy sics) Number of students enrolled in Algebra I in grade 7 (total count)24

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Number of students enrolled in Algebra I in grades: 8; 9&10; 11&12 (disaggregated b y race, sex, disability- IDEA, LEP) Number of students who passed Algebra I in grade 7 (total count) Number of students who passed Algebra I in grades: 8; 9&10; 11&12 (disaggregated b y race, sex, disability- IDEA, LEP) Number of students enrolled in Geometry in grade 8 (total count) Number of students enrolled in Geometry in grade s 9 - 12 (disaggregated b y race, sex, disability- IDEA, LEP) Number of students (grades 9 - 12) enrolled in other math and science courses, by subject (Algebra II, Advanced Math, Calculus, Biology, Chemistry, Ph ys ics) (disaggregated b y race, sex, disability- IDE A, LEP) Number of students who took SAT, ACT, or both, any time during school year (disaggregated by race, sex, disability- IDEA, LEP) GED H igh school equivalency exam preparation program (LEA) : Whether LEA operated a GED prep program Number of students ages 16 - 19 who participated in LEA - operated GED prep program (disaggregated b y race, sex, disability- ID EA, LEP) Number of students ages 16 - 19 who participated in LEA - GED operated prep program, succeeded on GED test, and received high sc hool equivalency credential (disaggregated by race, sex, disability- IDEA, LEP) Whether LEA has policy

that allows retention of third grade students who are not proficient in reading (LEA) Number of students retained in specified grade, by grade (K - 12) (di saggregated b y race, sex, disability- IDEA; disability- 504 onl y, LEP) School finance (funded with state and local funds) K - 12 personnel FTEs and salaries at the school level (funded with state and/or local funds) Number of FTE teachers and amount of their salaries Number of FTE instructional staff (teachers & aides) and amount of their salaries Number of FTE support services staff for pupils and amount of their salaries Number of FTE support services staff for ins tructional staff and amount of their salaries Number of FTE school administration staff and amount of their salaries Number of FTE non - instructional staff and amount of their salaries Total amount of non - personnel expenditures at the school level Teachers (funded with federal, state, and/or local funds) Number of FTE teachers (preschool through grade 12) Number of FTE first - ye ar teachers (preschool through grade 12) Number of FTE second - ye ar teachers (preschool through grade 12) Number of FTE teachers abs ent more than 10 school day s (excluding professional development) (PS - 12) Other staff (funded with federal, state, and/or local funds) Number of FTE school counselors (preschool through grade 12)25

ICRAS ICR ID and OMB Number: (XXXX.XX) 1870 - 0504 RI N Number: XXXX - XXXX (if applicable) Number of FTE ps ychologists (preschool through grade 12) Number of FTE social workers (preschool through grade 12) Number of FTE security

guards (preschool through grade 12) Number of FTE school resource officers (preschool through grade 12) Number of FTE sworn law enforcement officers (preschool through gra de 12)