Comments on Mandatory Civil Rights Data Collection

On Sep 19, 2019, the U.S. Department of Education (ED) requested comments on a proposed revision to multiple aspects of the Civil Rights Data Collection (CRDC). With the stated goal of reducing unnecessary burden on school districts and quelling redundancies in data collection, the proposal included the elimination of multiple data points around early childhood education, English learners, school finance, educators, and harassment and bullying. On November 18, 2019, New America’s Education Policy Program submitted these comments to the Department of Education raising questions and urging reconsideration of many of the proposed changes.

In these comments, New America strongly opposed removing most of the data points suggested for elimination, making the case that these data are necessary and useful for protecting children’s civil rights and improving the quality of schooling for our nation's students broadly. For example:

• The administration recommends discontinuing the disaggregation of preschool enrollment data by race, sex, disability-IDEA, and English learner status. Preschool and early learning are imperative for children’s healthy cognitive, physical, and emotional development. Enrollment data broken down by race, ability status, and language level are crucial to ensure that all subgroups have equal access to these critical experiences. The ability to disaggregate data by subgroups is needed to accurately analyze access.
• The administration also proposes eliminating the collection of data around novice teachers. These data allow the government and the public to identify inequities in the distribution of inexperienced teachers, who are less likely to serve students well. It is because of the CRDC that we know that Black, Latino, American Indian and Native-Alaskan students are three to four times more likely to attend schools with higher concentrations of first-year teachers than white students. We also know that English learners also attend these schools at higher rates than native English speakers. If the Department eliminates this data collection, we will no longer have access to valuable school-level information about which groups of students and schools lack access to more experienced teachers.

New America believes that ED could retain these data (and the numerous additional data points outlined in our comments) while still meeting its goal of reducing burden by updating how the data collection system itself functions. Instead of simply adding and eliminating data points from these collections, agencies should find a way to leverage technology to align and connect datasets. One potential solution is to require contractors collecting and storing SEA and LEA data to create an Application Program Interface (API) that enables the datasets to talk to one another. This simple requirement, which should be stated in requests for proposals, would allow agencies to continue collecting comprehensive data and avoid redundancies and time-consuming reporting.

You can read the entirety of New America’s comments here.