Use of Part B Program Funds for Technical Assistance to States on IDEA Data Collection

U.S. Secretary of Education Betsy DeVos believes high-quality data are an essential part of local, State, and Federal efforts to improve outcomes for infants, toddlers, children, and youth with disabilities. The Office of Special Education and Rehabilitative Services (OSERS) is seeking input from the public, particularly State educational agencies (SEAs) and State lead agencies (LAs), on how best to provide technical assistance (TA) to States on the collection and reporting of data required under Part B, Section 618 and Section 616, of the Individuals with Disabilities Education Act (IDEA), including input on the most effective and efficient method of funding this TA. Currently, that TA on IDEA Part B and C data collection is provided to SEAs and LAs through funds reserved by OSERS under IDEA section 616(i) of Part B.

As a matter of general practice, the Department regularly reviews its investments to ensure that they represent the most efficient and effective use of federal funds. As part of this process, the Department is exploring several options for providing TA to States on collecting and reporting data required under Sections 618 and 616 of IDEA, and we are seeking input on whether to pursue these options.

The options are:

  1. Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618;
  2. Inviting SEAs and LAs to directly apply for funds reserved under Section 616(i) (Part B) to purchase TA to improve their capacity to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618;
  3. Reducing funds reserved under IDEA Section 616(i) (Part B) to fund national TA Centers to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618 and increasing slightly the IDEA Part B formula funding to States under Section 611(d);
  4. Not reserving funds under IDEA Section 616(i) (Part B) for TA for IDEA Part B and Part C data collection and instead including the funds in the IDEA Section 611 formula grant; and
  5. Allowing States to reserve additional State set-aside funding for IDEA Part B State-level activities, which would be used to improve the collection, analysis, reporting, and use of data under IDEA Part B (not Part C) instead of reserving funds under IDEA Section 616(i) (Part B).

To help us in our review, we ask that you address the following questions in the comment section below. To protect your privacy and the privacy of others, please do not include personally identifiable information, such as a name of a child or school personnel, a Social Security number, an address, a phone number or an email address in the body of your comment. Comments containing the aforementioned information will not be allowed to remain on this site.

This blog will be open for comments from April 24, 2018 through May 24, 2018.

  1. What challenges does your State face in collecting, analyzing, reporting, and using IDEA Part B and Part C data required under IDEA Sections 616 and 618?
  2. To what extent do current Department-funded investments under the TA on State Data Collection program help your State address those challenges?
  3. Are there other investments that the Department should pursue to meet States’ IDEA data TA needs, and how should these investments be funded?
  4. What do you believe would be the potential benefits or limitations of the following TA funding options:

a) The Department continues to reserve funds under IDEA section 616(i) (Part B) to fund national TA centers to support the IDEA Part B and C State Data Collection Program;

b) States apply directly for funding under the TA on IDEA Part B and C State Data Collection program, which they can use to purchase TA on IDEA data collection required under IDEA Parts B and C; and

c) The Department does not reserve funds under IDEA section 616(i) (Part B) to fund new awards under the TA on State Data Collection Program under IDEA Part B and C and instead provides additional direct, formula funding to States under Part B of the IDEA? This option could also include allowing States to reserve additional State set-aside funding for IDEA Part B State-level activities, which would be used to improve the collection, analysis, reporting, and use of data under IDEA Part B (not Part C).

Background

Since 1976, IDEA has required States to annually report data on children with disabilities and, during that time, the Federal government has provided TA to States to meet those requirements. In 2004, Congress added IDEA Section 616 to require States to submit to OSERS, and make available to the public, a state performance plan (SPP) and an annual performance report (APR) with data on how each State implements both Part B and C of the IDEA to improve outcomes for infants, toddlers, children, and youth with disabilities. In 2004, Congress also added IDEA section 611(c), which gave the Secretary the authority to reserve up to one half of 1 percent of the amounts appropriated under Part B of the IDEA for each fiscal year to provide TA under IDEA section 616(i), where needed, to improve the capacity of States to meet the IDEA data collection requirements. The maximum amount the Secretary may reserve under this set aside for any fiscal year is $25,000,000, cumulatively adjusted by the rate of inflation. In fiscal year 2017, the Department reserved $21,400,000 for these purposes.

Since 2007, the Department has used these funds to support the TA on State Data Collection program, which is designed to improve the capacity of States to meet their IDEA data collection and reporting requirements for both Parts B and C of IDEA under IDEA Sections 616 and 618. The Department currently supports six investments under this program: the Center for IDEA Early Childhood Data Systems (DaSy), the IDEA Data Center (IDC), the Center for the Integration of IDEA Data (CIID), the Center for IDEA Fiscal Reporting (CIFR), the National Center for Educational Outcomes (NCEO) (jointly funded with OSEP’s Technical Assistance and Dissemination Program), and the EDFacts Technical Support Services II contract (jointly funded with the National Center for Education Statistics).

Conclusion

OSERS appreciates your support and suggestions as we continue efforts to improve the collection, analysis, reporting, and use of data as required in Sections 618 and 616 of IDEA as part of our commitment to ensure that infants, toddlers, children and youth with disabilities and their families have the supports and services guaranteed under IDEA.

We look forward to receiving your comments on or before May 24, 2018.

64 Comments

  1. South Carolina is in favor of option #1, continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618. As a new data manager, the TA Centers has been instrumental in making sure we understood the process and the required data elements. We have worked with multiple TA Centers for data collection, reporting and funding. Utilizing the TA Centers gave a sense of empowerment and control. It also improved our knowledge base and created a user friendly environment where we could ask questions and not feel judged or isolated. They have assisted us in working through various problems and issues that we have experienced. It provided a platform where could network, while reducing stress and anxiety.

  2. I would like to take this moment to express my appreciation to OSEP for funding these TA Centers to provide support to SEAs regarding, data collection and reporting, fiscal responsibilities, programming, policy development, etc. Delaware has utilized these TA Centers extensively. The TA providers have been courteous and responsive to our needs and requests at a moments notice. They are the experts that are supported by OSEP.
    My request is to have OSEP continue to provide support to SEAs through the continuation of supporting these Centers through IDEA funds.

  3. As the Director for Special Education Programs in South Dakota (SD), I appreciate the opportunity to respond and provide feedback on the use of funds to support states. SD has been and will continue to be an active participant and extensive user of the OSEP-funded TA Centers. The TA Centers provide direct support, tools and resources to states, and serve as hubs of technical expertise that SD would not otherwise have immediate access to. These TA centers are a key resource in an ever changing regulatory environment, particularly when coupled with staff turnover at the state-level. This continuous change of requirements at the federal level and state level staffing makes it imperative to have consistent technical assistance that is easily accessible and provides consistency across states and topical areas.

    Changing the funding or structure of the federally funded technical assistance is counterproductive, as it assumes the states have the resources and time to address technical issues with the IDEA implementation as they arise. Under the proposed approach, smaller states would receive fewer funds, yet our federal implementation and reporting requirements are the same as larger states with scientifically less staff and resources available to meet those requirements. An inability to access technical assistance in a timely manner could jeopardize the ability of small states in particular to fulfill the requirements of the law. Changing the funding structure does more than change how funds are distributed, it reduces the expertise available to states. Without the assistance of TA Centers, the ability to implement research-based and data informed changes to our K-12 system to improve student outcomes would be challenging.

    Furthermore, the TA centers have the knowledge and information to facilitate states learning from one another. If OSEP choose to give these funds directly to the states, there will be no opportunity for cross-state learning nor would states be able to see how they can improve the quality of their data and reporting by learning from experiences other states. SD has particularly received benefit from participation in the NCSI cross state collaboratives and Fiscal Forums. SD would be in support of expanding the facilitation of state meetings in order for program specialists at the state level to be able to connect with one another as content experts along with TA Center staff. Peer-to-peer learning, receiving a consistent message and networking opportunities at these meetings provide the most direct benefit to state level teams.

    As a recommendation, currently there is overlap in content and staff between the various TA Centers, for example both CIFR and NSCI have a fiscal component to their work and there is some overlap. Iin some cases it is not clear which TA Center should be the main point of contact. This can lead to confusion. The overlap could be reduced by combining some of the TA Centers, so that a smaller number of TA Centers have a broader, clearer focus. This could also help reduce the number of TA Center points of contacts that states have. Although this confusion and overlap has existed, SD has always received quality customer support and has found that TA Centers work collaboratively to ensure the question is addressed to our satisfaction.

    Thank you for the opportunity to provide feedback. I hope OSEP will carefully consider the feedback provided in determining the best way to support states in an equitable fashion.

  4. In my experience as a researcher and educator the current technical assistance centers provide a wealth of information that the field uses on a daily basis. To reduce funding to them, or worse eliminate them, would mean a loss of critically needed information about the state of our field, especially students with disabilities. Furthermore, the existence and consistency of the centers has provided a longitudinal view of the field and the needs going forward. They have each kept up with cutting-edge research and innovation to further develop assessment and instruction for all learners including universally designed assessments. The centers need to be part of the national conversation on special-education and individuals with disabilities.

  5. OSEP-funded Technical Assistance (TA) Centers currently provide direct support, tools and resources to states, and serve as sources of technical expertise. Over the years, Minnesota Department of Education (MDE) staff have used a variety of resources and tools over the years from all of the TA centers identified for comment: Center for IDEA Early Childhood Data Systems (DaSy), the IDEA Data Center (IDC), the Center for the Integration of IDEA Data (CIID), the Center for IDEA Fiscal Reporting (CIFR), the National Center for Educational Outcomes (NCEO), and the EDFacts Technical Support Services. These TA centers have become a key resource in an ever changing regulatory environment, especially as federal special education data reporting requirements are continually changing and expanding. To manage the amount of change across all these required monitoring and reporting, especially considering the rates of state staff turnover, it is essential to have consistent, clear technical assistance that is available to all states and territories. In addition, the need for high-quality technical assistance is needed in all areas of data collection and use, including analysis, improvement, evaluation, and reporting. As states and territories vary widely in their individual staff resources and capacity to understand, coordinate, and manage the complex information and systems required of us, it is critical that OSEP continue to support funding the TA Centers so they can continue to provide support and increase the capacity of states to meet our IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    For example, the IDEA Data Center (IDC) staff and publications have been a critical resource to the data manager and other staff who support State Performance Plan/Annual Performance Report data collection and reporting. Products and publications such as those for new data managers, data process documentation, and in-depth TA guides are just some examples of critical resources used that could not be developed or would be too time-intensive for state staff to do on their own.

    In addition, the MDE special education monitoring team having the opportunity to utilize technical assistance from Center for IDEA Fiscal Reporting (CIFR). We have had challenges in interpreting regulation as well as how to implement certain aspects of regulation. Even in cases where the questions were not directly under the specific TA guidance CIFR offers, they provide forums where SEA staff can easily reach out to others for help and they are happy to provide some basic direction even on those topics outside of their umbrella. The fiscal forums they have hosted have provided a wealth of knowledge and resources of which SEA staff may not be aware or have time to research and may not have learned about without CIFR support. Ongoing funding for CIFR will provide continued benefit those in the field. While CIFR tools may not be utilized by all SEAs or all our SEA staff, we are aware of many who do use them and have found them beneficial. In addition, CIFR is able to get answers to SEAs more quickly than ever before and they have helped create supportive communities where SEA staff can get answers to a variety of questions. CIFR as a centralized resource facilitates that opportunity; without that SEA staff would likely fall back into isolated methods and progress would slow. Passing funds on to SEAs to apply for TA or increase their set aside will not have the same level of support or impact. Requiring SEAs to apply for TA funds creates an added layer of work that demands staff time, ability, and internal support; increasing an administrative barrier where some states may never apply. Increasing SEA set-asides potentially creates other issues, diluting the resources that would otherwise support the specific fiscal TA CIFR provides. We believe funding should remain for CIFR and support the exploration and possibility for states to apply for grants through CIFR that would support helping the states update technology or personnel systems so they can better collect, utilize, and improve results using the data.

    MDE also has participated in two cross-state learning collaboratives facilitated by the National Center for Systemic Improvement (NCSI). The work generated by the Results-Based Accountability collaborative has been immensely helpful in moving Minnesota toward student results as part of its general supervisory authority. Participants in the collaborative strongly feel Minnesota’s progress is primarily the result of NCSI’s guidance and insight learned from other states’ experiences. Participation in the Graduation and Post-School Outcomes collaborative has been an important asset to support the implementation of Indicator 17, our State Systemic Improvement Plan (SSIP); by having the opportunity to network and collaborate with participating states it provides strength learning improves The relationships developed in the course of this work also promise to yield more benefits as Minnesota continues to collaborate with other states. In addition, MDE’s partnership with the State Implementation and Scaling-up of Evidence-based Practices (SISEP) Center has provided MDE with significant, ongoing support in its SSIP implementation work through the use of implementation science to implement and scale-up evidence-based practices to improve graduation outcomes for students with disabilities. Through the support and coaching of SISEP, we are building the capacity of state and district staff to implement and scale up effective education innovations statewide and ensure that every student can benefit from the intended outcomes.

  6. In my role as Nevada’s State Superintendent of Public Instruction, and in collaboration with our State Special Education Director, Will Jensen, I appreciate the opportunity weigh in on this important matter. Nevada is making significant strides to increase the degree to which we support all students in reaching equitable, positive outcomes. Among our strategic priorities for our students with disabilities, we are focused upon increasing successful inclusive practices for preschoolers; achieving targeted literacy results for students by the end of 3rd grade and beyond; continuing our emerging trend to increase graduation rates for students with high incidence disabilities; and starting to address more intensely the needs of our low incidence students as they graduate from high school and transition to successful post-secondary outcomes.

    Each of these priorities requires a firm reliance on access to and use of high quality data (programmatic and fiscal) to work in partnership with key stakeholders to inform our decision making about policy development, resource allocation, implementation of evidence-based practices, and other essential considerations associated with systemic improvement and transformation. The technical assistance we receive through OSEP’s national TA centers is immensely beneficial to our efforts to succeed in meeting our goals. Accordingly, I strongly endorse Option 1, as articulated in the OSERS description posted above. The other options listed, while intriguing, create more challenges than they do opportunities, for us to succeed in reaching our mission and the goals established in our Nevada State Improvement Plan (STIP), State Systemic Improvement Plan (SSIP), and ESSA Plan.

    We have benefited directly and strategically, from each of the 5 centers named by OSERS (i.e., CIFR, CIID, DaSy, IDC, NCEO). Without the support of these centers (and key others, such as NCSI and NTACT), our state would likely not have achieved the goals we have, in the time we have, to the degree of success that we have done. My staff, and our stakeholders as partners, markedly benefit from the capacity-building efforts that exist as a result of our engagement with each of these centers, and I agree with the numerous comments posted on this blog, stating our backing for OSERS to continue to fund national TA centers, as articulated in Option 1.

  7. The 28 undersigned members of the CCD Education Taskforce thanks you for the opportunity to comment on the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) question on how to best provide technical assistance (TA) to states, and also the most effective and efficient method for funding the TA.

    CCD is the largest coalition of national disability organizations and the CCD Education Task Force advocates for Federal public policy that ensures the self-determination, independence, empowerment, integration, and inclusion of children and adults with disabilities in all aspects of society. The CCD Education Task Force sees these principles as critical elements in a society that recognizes and respects the dignity and worth of all its members.

    In its blog post OSERS outlined four options regarding providing TA to States on collecting and reporting data required under Sections 618 and 616 of IDEA. The undersigned feel strongly that the Department should continue with Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618; for the reasons stated below:

    • The TA centers, as currently funded, have provided tremendous assistance to help ensure that the data collected is valid and reliable and reported in a manner that enables states to make important policy decisions to ensure that states and locals meet requirements under the Individuals with Disabilities Education Act (IDEA).

    • The TA centers have the expert knowledge and information to facilitate states learning from one another which is critical when resources are scarce and the IDEA is not fully funded.

    • Currently, the TA centers are funded at 21M; dividing and dispersing this amount to all states on the 611 formula will result in the dispersed dollars having little impact. Additionally this option would eliminate national Part C data technical assistance since these funds would be reallocated to Part B grants, only.

    • A change in the funding structure would result in an inequitable distributions of funds to every state. Smaller states would receive less dollars although their reporting requirements are the same as larger states.

    • Giving the funds to states to purchase TA is problematic, there will be overhead in each state as states will have to make awards to vendors who would provide the TA.

    • The model of each state providing TA on data collection would result in redundancy in product development and other work across the states that National Centers generally minimize.

    • As noted in the comments submitted by NASDSE states have indicated that they support and value the TA centers.

    The critically important support provided to states by the Part B funded TA Centers can be exemplified by three projects at the National Center on Educational Outcomes (NCEO):

    1. Support for a Community of Practice of 30 states with 69 state personnel on data collection and topics related to their implementation of the 1% cap on participation in alternate assessments based on alternate achievement standards. The number of states exceeding the cap makes it clear that they need this TA from NCEO.
    2. Development of intensive technical assistance plans with states on their State-Identified Measurable Results (SIMRs).
    3. Working with States to support their understanding of how to effectively use local assessment data within a larger state assessment and accountability system.

    The undersigned firmly believe that in addition to the financial, logistical and other challenges described above, OSEP’s monitoring, technical assistance, and accountability for implementing IDEA would be weakened as the quality of data collected and reported diminishes.
    Additionally, a reduced or weakened Federal role likely means lower compliance with the IDEA and reduced commitment to the education of students served under the IDEA. As such, we strongly suggest that the Department continue with Option 1.

    Sincerely,

    ACCSES
    American Foundation for the Blind
    American Physical Therapy Association
    American Speech-Language Hearing Association
    Association of University Centers on Disabilities (AUCD)
    Conference of Educational Administrators of Schools and Programs for the Deaf
    Council for Exceptional Children
    Council for Learning Disabilities
    Council of Administrators of Special Education
    Disability Rights Education & Defense Fund
    Division for Early Childhood of the Council for Exceptional Children (DEC)
    Easterseals
    IDEA Infant Toddler Coordinators Association (ITCA)
    Learning Disabilities Association of America
    National Association of Councils on Developmental Disabilities
    National Association of Councils on Developmental Disabilities
    National Association of School Psychologists
    National Association of State Head Injury Administrators
    National Center for Learning Disabilities
    National Center for Special Education in Charter Schools
    National Disability Rights Network
    National Down Syndrome Congress
    RespectAbility
    School Social Work Association of America
    TASH
    The Advocacy Institute
    The Arc of the United States
    Tourette Association of America

  8. West Virginia regularly utilizes support from the following five technical assistance centers: the IDEA Data Center (IDC), the IDEA Early Childhood Data Systems (DaSy), the Center for the Integration of IDEA Data (CIID), the Center for Fiscal Reporting (CIFR) and the National Center for Educational Outcomes (NCEO). We are working with CIID to assist us in utilizing the Generate Tool to improve our EDFacts data. Information from CIFR has supported our office in the area of State Maintenance of Financial Support. Personnel from IDC have spent multiple days in West Virginia training our data manager. The resources provided by NCEO have assisted us in developing our Alternate Diploma and implementing strategies to meet the 1% State-level cap on participation in the Alternate Assessment.
    As a small state we encourage the Department to use funds to continue to support the six investments in technical assistance for the State Data Collection Program. The money provided to WV would not be adequate to be able to obtain the quality of service that is being provided by the Centers. Speaking as the Part B State Director the relationships with these Centers have improved our quality of data and the capacity to meet our IDEA Part B data collection requirements.
    Please consider Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616 (i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Section 616 and 618.

  9. PACER Center is the Parent Training and Information Center (PTI) for Minnesota and a National Parent Center. At PACER, we have successfully strengthened and systemically improved parental engagement and services for students and young adults with disabilities in Minnesota and around the country. Our work through a center approach has produced positive and long-lasting results and is the cornerstone of improved student achievement and family outcomes in our schools and communities.

    PACER has decades of experience being a federally-funded national technical assistance provider, including developing a national data collection system for the more than 100 OSEP-funded Parent Centers. Based on this expertise, we are pleased to submit comments on the how the U.S. Department of Education (ED) should provide TA to States in collecting and reporting data under sections 618 and 616 of the Individuals with Disabilities Education Act (IDEA).

    In its notice ED lays out five options for which input is being collected to provide this technical assistance. The first, and current approach, is to continue to fund national technical assistance Centers. We favor this option as it provides the greatest chance for the technical assistance provided to states to be high quality and consistent across the states. Having states select or fund their own technical assistance providers, reducing center funding, sending more funding down through formula grants or allowing states to use Part B funds to improve collection and other activities would fall short of providing the consistency and quality we have experienced through a center approach.

    The center-based model provides for a consistent approach to technical assistance across state data collection and reporting when uniformity of such collection and reporting is paramount. While there is natural variation in how States report on different aspects of IDEA, the use of technical assistance centers should reinforce a common use of definitions and approach to bring as much “apples to apples” comparison as possible.

    The quality of the technical assistance provided through a center-based approach is also important. Under the other approaches listed by ED, a single quality control mechanism would be lacking. States selecting their own providers or choosing to use IDEA resources to strengthen data capacity through individual contractors would increase the likelihood of uneven and lower quality technical assistance than is currently provided through a center-based approach. Continuing to fund national centers would help ensure high quality TA and reliable data.

    Thank you for considering our views on this topic.

  10. From its perspective as a provider of TA to states and LEAs, and a leading researcher around how to leverage digital learning for the benefit of students with disabilities, CAST recommends that the Department pursue Option 1 and continue to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    As online and otherwise networked digital learning increasingly becomes commonplace in the nation’s K-12 schools, the widespread and consistent use of commonly-accepted data structures (like CEDS at https://ceds.ed.gov/, for example) to identify and document both students and services becomes increasingly important. In some circumstances, existing data structures related to the provision of IDEA-mandated service designation and delivery are LEA-specific, and this localization becomes a component of the LEA’s networked digital learning systems. Challenges exist as digital learning becomes increasingly multi-faceted (apps, 24/7 access; mobile devices, etc.). The use of common data structures within a state is critical to ensuring accurate reporting, and a unified and national data system will likely emerge as a necessary to assure valid IDEA documentation.

    CAST believes the Department is in a unique position to guide and fund national TA Centers to support a more unified and consistent approach to 1) the identification of students with disabilities; 2) the type and duration of special education services provided to these students, and 3) the relationship of this service provision to student academic progress.

    Without consistent and widely-used data structures the collection of accurate data related to these three items is unlikely; and designing and maintaining a system that supports these outcomes would be difficult, if not impossible, to achieve on a state-by-state basis. As such, the continued support of national TA centers is a worthwhile investment for the Department to make.

  11. 1. What challenges does your State face in collecting, analyzing, reporting, and using IDEA Part B and Part C data required under IDEA Sections 616 and 618?
    This is not an exhaustive list, but some of the key challenges Kansas face includes:
    1) Staying abreast of changes in regulation, statutes, court interpretation, and federal guidance;
    2) Identifying and implementing best practices;
    3) Turnover of SEA staff and the need to train new staff and build capacity of existing staff;
    4) Communicating the need for, and interpretation of data to stakeholders at both the LEAs as well as policy makers;
    5) The need for critical friends to assist in the review of current practices to identify deficiencies and opportunities for improvement; and
    6) The risk that Improper implementation of IDEA requirements could result in the loss of funding or interfere with children’s ability to receive FAPE

    2. To what extent do current Department-funded investments under the TA on State Data Collection program help your State address those challenges?
    Below are a few specific examples, by center. This is only intended to illustrate some of the many supports each center has provided Kansas. Many of the benefits provide by these national centers, such as the convening of multi-state supports and CoPs, is only possible because these are national centers funded by OSERS. These are benefits that no state, on its own, could purchase at any price, were these centers to cease. Please also note that while the examples are broken out by center, some of the greatest supports occur when the centers collaborate in the delivery of comprehensive TA, as they often do.
    • Center for IDEA Fiscal Reporting (CIFR)
    1. The center has developed multiple slide-decks, short educational videos, and related out-of-the-box resources that SEAs may customize to better educate stakeholders on key IDEA fiscal concepts, which in-turn result in the improved collection and use of data.
    2. CIFR staff have provided ongoing support developing and assisting our SEA personnel in the creation of meaningful process documents that address everything from Maintenance of Effort, to the Application for Funds, to the Collection of related fiscal data.
    3. CIFR manages regional Communities of Practice (CoP) that convene virtually every month
    4. The center Convened two biennial national meetings in which center staff, OSERS, other IDEA funded TA Centers, and SEA personnel have presented. These meetings have consistently include timely clarification on requirements, evolving best practices, and the sharing of tools and resources.

    • National Center for Systems Improvement (NCSI)
    1. Manages multiple communities of practice (CoP) in which Kansas regularly participates, including the Results Based Accountability collaborative and the Systems Alignment Learning Collaboriative.
    1. These active CoPs strike the right balance of face-to-face meeting with center staff and other states, as well as more frequent virtual meetings.
    2. The CoPs are an excellent means by which states may learn from each other and share tools and resources.
    • Center for Integration of IDEA Data (CIID)
    1. Facilitated collaborative, cross-team data mapping and data integration training with our SEA staff
    • IDEA Data Center (IDC)
    1. Provided training for our SEA staff on how to use and understand the data that is collected to improve the quality of the data that is collected from LEAs and improve results for students
    2. Convened multiple national meetings in which IDC staff, OSERS, and SEA personnel have presented. These meetings have consistently include timely clarification on requirements, evolving best practices, and the sharing of tools and resources.
    3. Are there other investments that the Department should pursue to meet States’ IDEA data TA needs, and how should these investments be funded?
    Not necessarily new investments, but centers should be given appropriate latitude to collaborate together, where appropriate, in order to better meet state needs, and promote opportunities for center collaboration across federal programs. This a natural evolution and a reflection of the how the work is performed at both the SEA and LEA level.
    The Department should look at this model of providing TA and consider applying the lessons learned to other programs, such as to the new State Support Network that supports SEAs in the implementation of ESEA.
    4. What do you believe would be the potential benefits or limitations of the following TA funding options:
    a) The Department continues to reserve funds under IDEA section 616(i) (Part B) to fund national TA centers to support the IDEA Part B and C State Data Collection Program; Option 4a is the preferred option of Kansas for all of the reasons stated above, and the only option that is reasonably calculated to maximize OSERS leveraging of these funds.

    b) States apply directly for funding under the TA on IDEA Part B and C State Data Collection program, which they can use to purchase TA on IDEA data collection required under IDEA Parts B and C; and
    This option would result in diminished quality of data and results for children nationwide for the following reasons:
    1) States that most need the support would be least aware of their lack of knowledge;
    2) Piecemeal services will result in lower overall quality – once dismantled, there would be no viable alternative to the current TA centers;
    3) Breaking up the centers would bring an end to effective peer to peer collaboration and communities of practice;
    4) Taxpayers will ultimately be paying more nationwide, as each state would need to develop more resources and tools from scratch, rather than accessing nationally developed resources, or having access to materials from other SEAs; and
    5) Many of the most valuable collaborative supports noted above simply cannot be implemented at a state level.

    c) The Department does not reserve funds under IDEA section 616(i) (Part B) to fund new awards under the TA on State Data Collection Program under IDEA Part B and C and instead provides additional direct, formula funding to States under Part B of the IDEA? This option could also include allowing States to reserve additional State set-aside funding for IDEA Part B State-level activities, which would be used to improve the collection, analysis, reporting, and use of data under IDEA Part B (not Part C).
    In addition to every concern noted in 4b, redistributing these limited funds amongst all SEAs would render them completely ineffectual. Even if 100% of this additional funding was reserved at the state level, the type and quality of services that could be procured would pale compared to what is currently available. Further watering down this resource by flowing it to the LEAs would only exasperate the effect, as many LEAs in Kansas might see an increase of only a few thousand or even a few hundred dollars. LEAs and SEAs do need additional financial resources to continue to improve outcomes for all students under IDEA, but given this choice, the cost would outweigh the current benefit.

  12. The Council of Parent Attorneys and Advocates (COPAA) appreciates the opportunity to comment on the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) request for input on the collection and reporting of data required under Part B, Section 618 and Section 616, of the Individuals with Disabilities Education Act (IDEA), including input on the most effective and efficient method of funding this technical assistance (TA). COPAA is an independent, nonprofit organization of parents, attorneys, advocates, and related professionals. COPAA members nationwide work to protect the civil rights and secure excellence in education on behalf of all children with disabilities under the Individuals with Disabilities Education Act (IDEA) and those provided 504 plans under Section 504 of the Rehabilitation Act of 1973 in America. Our mission is to serve as a national voice for special education rights and is grounded in the belief that every child deserves the right to a quality education that prepares him or her for meaningful employment, higher education and lifelong learning, as well as full participation in his or her community.

    Our recommendations are as follows:

    1. Continue with Option 1, funding national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    2. Build on the capacity of TA providers to help states meaningfully comply with all requirements of IDEA, the Every Student Succeeds Act (ESSA), The Workforce Investment Opportunity Act (WIOA), the Higher Education Act and all other federal statutes, related programs and associated regulations impacting the status and outcomes of children with disabilities. Though states are making progress for students with disabilities, the data are quite clear that major gaps exist. The outcomes exhibited in the data should guide TA from OSERS through the Office of Special Education (OSEP) to states in strategic and impactful ways.

    a. States must meet all requirements under IDEA. OSERS/OSEP is required to fulfill its obligation to monitor compliance with IDEA and work with states when data [and practice] show specific and potential systemic violations of the law. With this examination of how TA is implemented to support states, COPAA urges OSERS/OSEP to step up its efforts to help states comply, promote excellence and support innovation so that children can achieve the results we know lead to high school graduation, career training and/or matriculation into post-secondary education and independent living. For example, it is disturbing that OSEP allowed actions led by the Texas Education Association to occur even when data and reports showed there were significant issues throughout Texas districts. And, the recent practices in Chicago Public Schools demonstrates the OSEP can and should be doing more with the data and with TA partners so that states can fulfill all obligations under IDEA. It’s unfortunate, but states and districts, too often do not self-monitor and use the data to seek assistance so that school and district teams teach and support children with disabilities.

    b. Congress, with consistent bipartisan support, has actively worked with parents and advocates to align all education laws (e.g. IDEA, ESSA, WIOA etc.) and made explicit how the intentional intersections are meant to raise expectations and support the achievement of students with disabilities. Therefore, data collected under IDEA Part B and Part C Sections 616 and 618 should be used by OSERS/OSEP to work closely with states [and TA partners] to integrate statutory requirements [and related programmatic priorities] into State ESSA plans, state systemic improvement plans, state professional development plans, WIOA state plans, teacher preparation programs and more. Special education should not be an afterthought as states design their educational priorities and braid funds to serve students. OSERS/OSEP in partnership with the Office of Elementary and Secondary Education must help states move forward in this goal.

    c. TA partners are critical in using data to design meaningful support for states. Examples from the National Center for Educational Outcomes (NCEO) are:
    i. Compiling data, designing and providing resources so states can train school teams to assure students achieve grade level standards via their uniquely designed Individualized Education Programs (IEPs).
    ii. Providing training and assistance to states who need to comply with ESSA’s requirements regarding the state cap at 1 percent cap of all students participating in alternate assessments on alternate achievement standards.
    iii. Working with States to support their understanding of how to effectively use local assessment data within a larger state assessment and accountability system.

    We urge OSERS/OSEP to maintain Option 1 and do more with the data and TA partners as discussed so that states work intentionally to help all students with disabilities achieve meaningful outcomes.

  13. Wisconsin supports continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618. The assistance, tools and support provided from the national TA centers have played an integral role in improving the quality of the data collected to meet the federal reporting requirements. It would be difficult to replace the knowledge and information that is regularly communicated from TA Center staff to SEA staff. Specifically, related to future direction, staff would appreciate more assistance on the use of the Child Outcomes (Indicator 7) data to support program improvement.

  14. As the ECSE Supervisor in Minnesota, responsible for Part C and Section 619 I fully support Option #1. I believe that Minnesota’s early childhood special education program has benefited greatly from targeted TA received by entities such as the Early Childhood Outcomes Center (ECO), DaSY, IDC, etc… and know that we have upcoming support needs as we continue to grow our ability to collect and report high quality data and work to create cultures of data use at the state, regional and local program levels.

    I have found consistent value from interactions with staff from these specialty centers and know that our work in enhanced in terms of quality and efficiency because of these relationships.

  15. I have worked with the Kentucky Department of Education’s (KDE) Division of Learning Services (IDEA Part B) for 14 years. I began my employment with KDE as a staff attorney. After nine years, I became the division’s assistant director.

    I strongly support continued funding of OSEP’s Technical Assistance (TA) Centers (Option One), based in part on my experiences with the massive revisions that occurred within IDEA and OSEP since the early 2000’s and my subsequent involvement with the TA Centers. My first years at KDE were a period of significant changes with IDEA Part B, due in part to the 2004 IDEA Reauthorization. During this time, I was responsible for implementing KDE’s new self-assessment monitoring system required by OSEP. The self-assessment eventually became the State Performance Plan (SPP) which was required by the Reauthorization.

    To say this was a period of great angst for State Educational Agencies (SEAs) is an understatement. It was a time of learning new ways of implementing IDEA, especially the change from monitoring for regulatory compliance to focusing on student outcomes. States learned about focusing on results for students with IEPs, including collecting and analyzing data, evaluating results, developing logic models, learning about disproportionate representation and fiscal accountability, as well as proficiency for students with IEPs and their post-school outcomes. In short, these were issues that we, at the state level, had never been required to examine.

    We did not have staff who were knowledgeable about most of the new areas. We did not have research departments as some larger states had, nor did we have staff who could be solely devoted to learning these new areas, as we were “paddling” as fast as we could. While OSEP staff consistently offered states much needed help and technical assistance during this time, they too were learning a whole new system and were stretched for time.

    Fortunately, OSEP had funded TA centers pursuant to Part D of the IDEA for many years. The TA centers were a lifeline to the SEAs. They had staff experienced in areas in which states were not knowledgeable. If the topics were new to a TA center, there was a network of centers that worked together and developed the needed assistance for the SEAs.

    Experiences of the past inform the present – and the future. There are new IDEA issues that constantly come up, which states are required to address. Unfortunately for SEAs, budgets have been slashed to the bone. The inability to hire new staff because of budget cuts and hiring freezes means that, in Kentucky, the number of KDE special education consultants is at an all-time low.

    This is a critical situation that is, by no means, a problem unique to Kentucky. It is simply impossible for SEAs to comply with IDEA as well as to exercise their IDEA general supervision responsibilities over school districts without the help of technical assistance.

    Option 1 is the only option under which states can continue to receive high quality technical assistance which is critical to SEAs’ work. TA Centers have maintained talented staff who are experienced in every special education problem area. States are comfortable with TA Center staff, since many TA providers know the states’ context as well as the states’ staff. There are no long periods of SEAs and TA Center staff getting to know each other. The TA Centers have hit the ground running.

    Kentucky has been especially fortunate to have a beneficial relationship with the IDEA Data Center (IDC) over the past 4½ years. IDC has helped Kentucky with a myriad of issues to build state staff capacity, ranging from training and coaching related to the federal reporting requirements, including the SPP and APR, to developing processes for the collection, validation, analysis, and submission of Section 616 and 618 IDEA data collections. IDC’s excellent resources on its web site builds states capacity, even when IDC is not working directly in the state.

    IDC has brought experts to KDE to provide training on privacy and confidentiality. It has helped us brainstorm areas in which KDE was considering changes to its current data governance and management. KDE relied on IDC staff to assist us in better understanding significant disproportionality. Its staff helped us understand the right questions to ask, when KDE was monitoring a large urban school district in which suspensions over 10 days for African American students with IEPs was an issue.

    IDC has provided training throughout the years with issues in which technical assistance is difficult to obtain. A great example of this is the IDC Interactive Institutes (regional data conferences). Over the past three years, IDC has convened institutes across the country in “all things data”, focused on topics related to improving IDEA data quality. The institutes have been universally praised, with participants saying it is the best conference they have ever attended. It would be impossible for states to duplicate this work on their own, or to contract with individual TA providers.

    KDE has also greatly benefited from other national TA Centers. When KDE began contemplating its work for SPP Indicator 17 – the State Systemic Improvement Plan (SSIP) – we had the benefit of intensive technical assistance on implementation science from the State Implementation and Scaling-up of Evidence-based Practices (SISEP) Center. Implementation science is an evidence-based practice that is quite complex. Consultants from SISEP and its partner, the National Implementation Research Network (NIRN), have specialized in implementation science for many years. SISEP has used its expertise in assisting KDE in ground-breaking work.

    SISEP has provided on and off site technical assistance to KDE, local school districts and KDE’s regional cooperatives that are involved with our Indicator 17 work. SISEP has brought together other states and their partners who are involved in implementation science work, to learn from each other.

    As noted above about IDC, a network like SISEP cannot be duplicated by individual contractors or by individual states, both because of the complexity of implementation science (implementation science has its own language, its own system and its own tools to assist practitioners of the work) and the relationships SISEP has built over the years. If not for the assistance of SISEP, it would have been extremely difficult for KDE to scale-up its work under Indicator 17.

    My final “shout-out” is to the Center for IDEA Fiscal Reporting (CIFR). Several years ago, KDE found itself in a difficult situation involving Maintenance of State Financial Support (MFS), in which we were faced with a “payback” to OSEP of millions of IDEA dollars CIFR met with KDE numerous times and supported us during conference calls with OSEP.

    CIFR’s most intensive efforts involved work sessions in which their Part B financial experts examined KDE expenditures. CIFR discovered areas in which KDE had expended state funds to support the provision of special education and related services to students with disabilities, which had not been reported in KDE’s MFS report to OSEP.

    OSEP found the recently discovered state expenditures to be allowable, thus relieving KDE from paying back any of the millions of dollars originally found to be owed to OSEP. This was not a small issue – thousands of Kentucky students with IEPs would have been affected, had CIFR not assisted KDE. Other states have benefited from CIFR’s work in the same manner as KDE.

    To summarize, OSEP TA Centers:
    · Have unmatched expertise with IDEA issues that often bedevil the SEAs;
    · Are a brick and mortar operation that will not disappear upon the relocation, retirement or death of a staff member;
    · Have built a network that collaborates and works together for the good of their states;
    · Have services that are free to the states, which is vitally important in the age of shrinking budgets; and,
    · Have “jobs alike” training and programs which are critical for practitioners.

    If the TA Centers are replaced by private contractors or through extra funding to SEAs, OSEP and SEAs will have lost an irreplaceable resource. The TA Centers have spent extensive amounts of time and effort in becoming experts in their fields, knowing their SEA clients and scaling-up their projects. If any other TA options listed are funded and replace the TA Centers and then are not successful, SEAs will be in an untenable position.

    New TA systems cannot be built with a wave of a wand. The unprecedented work OSEP has been able to accomplish over the past years has been greatly aided by their partnership with TA Centers. If they disappear and are not successfully replaced, then who will assist the states — and OSEP?. It is frightening to imagine how SEAs would find expert resources needed for future new IDEA requirements.

    While the remaining options offered seem attainable in theory, they are not workable. As noted above, the option of providing funds to SEAs to contract for services is not practical. Contractors will typically not have the long standing expertise, experiences or relationships with states needed to provide intensive technical assistance.

    To refer to the examples above, finding contractors who have the understanding and expertise to consult with SEAs on IDEA data, disproportionate representation, the SPP/APR, implementation science and IDEA finance requirements would be difficult if not impossible. There would be no incentive for contractors to do the tasks TA Centers currently do to increase state capacity, such as developing resources and websites, providing training to groups of states and creating networks of experts. Moreover, if there are qualified consultants available, it seems likely that “supply and demand” would keep SEAs from being able to afford intensive, long-term services.

    Executing contracts within state government is not a quick or easy task, due to the time needed to move the contracts through the state bureaucracy. In Kentucky, there is the added issue of the oversight exercised by the state legislature. Contracts are routinely “pulled” by legislative committees, which then question state agencies such as KDE about the necessity and purpose of the contract.

    Options three through five give several iterations of providing IDEA funds to SEAs directly for the purchase of technical assistance. Although the concepts seems sound in theory, Kentucky would not benefit from these proposals in practice. The number of staff which can be hired within the Division of Learning Services and KDE is capped by the state. The limit on the number of employees does not allow Kentucky to hire additional staff, such as researchers or experienced practitioners, to fulfill the role of technical assistance providers.

    Thank you for the opportunity to comment. I urge you to continue funding technical assistance through the current system of funding Technical Assistance Centers.

    As the old saying goes, if it ain’t broke…
    The TA Centers are not broken. Please do not replace them.

    I have worked with the Kentucky Department of Education’s (KDE) Division of Learning Services (IDEA Part B) for 14 years. I began my employment with KDE as a staff attorney. After nine years, I became the division’s assistant director.

    I strongly support continued funding of OSEP’s Technical Assistance (TA) Centers (Option One), based in part on my experiences with the massive revisions that occured with IDEA and OSEP since the early 2000’s and my involvement with the TA centers. My first years at KDE were a period of significant changes with IDEA Part B, due in part to the 2004 IDEA Reauthorization. During this time, I was responsible for implementing KDE’s new self-assessment monitoring system required by OSEP. The self-assessment eventually became the State Performance Plan (SPP) which was required by the Reauthorization.

    To say this was a time of angst for State Educational Agencies (SEAs) is an understatement. It was a time of learning new ways of implementing IDEA, especially the change from monitoring for regulatory compliance to focusing on student outcomes. States learned about focusing on results for students with IEPs, including collecting and analyzing data, evaluating results, developing logic models, disproportionate representation, fiscal accountability, as well as proficiency for students with IEPs and their post school outcomes. In short, these were issues that we, at the state level, had never been required to examine.

    We did not have staff who were knowledgeable about most of these new areas. We did not have research departments as some larger states had, nor did we have staff who could be solely devoted to learning these new areas, as we were “paddling” as fast as we could. While OSEP staff consistently offered states much needed help and technical assistance during this time, they too were learning a whole new system and were stretched for time.

    Fortunately, OSEP had funded TA centers pursuant to Part D of the IDEA for many years. The TA centers were a lifeline to the SEAs. They had staff experienced in areas in which states were not knowledgeable. If the topics were new to a TA center, there was a network of centers that worked together and developed the needed assistance for the SEAs.

    Experiences of the past inform the present – and the future. There are new IDEA issues that constantly come up, which states are required to address. Unfortunately for SEAs, budgets have been slashed to the bone. The inability to hire new staff because of budget cuts and hiring freezes means that, in Kentucky, the number of KDE special education consultants is at an all-time low.

    This is a critical situation that is, by no means, a problem unique to Kentucky. It is simply impossible for SEAs to comply with IDEA as well as exercising their IDEA general supervision responsibilities over school districts without the help of technical assistance.

    Option 1 is the only option under which states can continue to receive high quality technical assistance which is critical to SEAs’ work. TA centers have kept talented staff who are experienced in every special education problem area. States are comfortable with TA center staff, since many TA providers know the states’ context as well as the states’ staff. There are no long periods of SEAs and TA center staff getting to know each other. The TA centers have hit the ground running.

    Kentucky has been especially fortunate to have a beneficial relationship with the IDEA Data Center (IDC) over the past 4½ years. IDC has helped Kentucky with a myriad of issues to build state staff capacity, ranging from training and coaching related to the federal reporting requirements, including the SPP and APR, to developing processes for the collection, validation, analysis, and submission of Section 616 and 618 IDEA data collections. IDC’s excellent resources on its web site builds states capacity, even when IDC is not working directly in the state.

    IDC has brought experts to KDE to provide training on privacy and confidentiality. It has helped us brainstorm areas in which KDE was considering changes to its current data governance and management. KDE relied on IDC staff to assist us in better understanding significant disproportionality and knowing the right questions to ask, when KDE was monitoring a large urban school district in which suspensions over 10 days for African American students with IEPs was an issue.

    IDC has provided training throughout the years in areas in which technical assistance is difficult to obtain. A great example of this is the IDC Interactive Institutes (regional data conferences). Over the past three years, IDC has convened institutes across the country in “all things data”, focused on topics related to improving IDEA data quality. The institutes have been universally praised, with participants saying it is the best conference they have ever attended. It would be impossible for states to duplicate this work on their own, or by contracting with individual TA providers

    KDE has also greatly benefited from other national TA centers. When KDE began contemplating its work for SPP Indicator 17 – the State Systemic Improvement Plan (SSIP) – we had the benefit of intensive technical assistance on implementation science from the State Implementation and Scaling-up of Evidence-based Practices (SISEP) Center. Implementation science is an evidence-based practice that is quite complex. Consultants from SISEP and its partner, the National Implementation Research Network (NIRN), have specialized in implementation science for many years. SISEP has used its expertise in assisting KDE in ground-breaking work.

    SISEP has provided on and off site technical assistance to KDE, local school districts and KDE’s regional cooperatives that are involved with our Indicator 17 work. SISEP has brought together other states and their partners which are involved in implementation science work, to learn from each other.

    As noted about IDC above, a network like SISEP cannot be duplicated by individual contractors or by individual states, both because of the complexity of implementation science (implementation science has its own language, its own system and its own tools to assist practitioners of the work) and the relationships SISEP has built over the years. If not for the assistance of SISEP, it would have been extremely difficult for KDE to scale-up its work under Indicator 17.

    My final “shout-out” is to the Center for IDEA Fiscal Reporting (CIFR). Several years ago, KDE found itself in a difficult situation involving Maintenance of State Financial Support (MFS), in which we were faced with a “payback” to OSEP of millions of IDEA dollars CIFR met with KDE numerous times and supported us during conference calls with OSEP.

    CIFR’s most intensive efforts involved work sessions in which their financial experts examined KDE expenditures. CIFR discovered areas in which KDE had expended state funds to support the provision of special education and related services to students with disabilities, which had not been reported in KDE’s MFS report to OSEP. OSEP found the recently discovered state expenditures to be allowable, thus relieving KDE from paying back any of the millions of dollars originally found to be owed to OSEP.

    This was not a small issue – thousands of Kentucky students with IEPs would have been affected, had CIFR not assisted KDE with its review. Other states have been assisted by CIFR in the same manner as KDE.

    To summarize, OSEP TA centers:
    · Have unmatched expertise with IDEA issues that often bedevil the SEAs;
    · Are a brick and mortar operation that will not disappear upon the relocation,
    retirement or death of a staff member;
    · Have built a network that collaborates and works together for the good of their
    states;
    · Have services that are free to the states, which is vitally important in the age of
    shrinking budgets; and,
    · Have “jobs alike” training and programs which are critical for practitioners.

    If the TA centers are replaced by private contractors or through extra funding to SEAs, OSEP and SEAs will have lost an irreplaceable resource. The TA centers have spent extensive amounts of time and effort in becoming experts in their fields, knowing their SEA clients and scaling-up their projects. If any other TA options listed are funded and replace the TA centers and then are not successful, SEAs will be in an untenable position.

    New TA systems cannot be built with a wave of a wand. The unprecedented work OSEP has been able to accomplish over the past years has been greatly aided by their partnership TA centers. If they disappear and are not successfully replaced, then who will assist the states — and OSEP?. It is frightening to imagine how SEAs would find expert resources needed for future new IDEA requirements.

    While the remaining options offered seem good in theory, they are not workable. As noted above, the option of providing funds to SEAs to contract for services is not practical. Contractors will typically not have the long standing expertise, experiences or relationships with states needed to provide intensive technical assistance.
    To refer to the examples above, finding contractors who have the understanding and expertise to consult with SEAs on IDEA data, disproportionate representation, the SPP/APR, implementation science and IDEA finance requirements would be difficult if not impossible. There would be no incentive for contractors to do the tasks TA centers currently do to increase state capacity, such as developing resources and websites, providing training to groups of states and creating networks of experts. Moreover, if there are qualified consultants available, it seems likely that “supply and demand” would keep SEAs from being able to afford intensive, long-term services.
    Executing contracts within state government is not a quick or easy task, due to the time needed to move the contracts through the state bureaucracy. In Kentucky, there is the added issue of the oversight exercised by the state legislature. Contracts are routinely “pulled” by legislative committees, which then question state agencies such as KDE about the necessity and purpose of the contract.
    Options three through five give several iterations of providing IDEA funds to SEAs directly for the purchase of technical assistance. Although the concept seems sound in theory, Kentucky would not benefit from this proposal in practice. The number of staff which can be hired within the Division of Learning Services and KDE is capped by the state. The limit on the number of employees does not allow Kentucky to hire additional staff, such as researchers or experienced practitioners, to fulfill the role of technical assistance providers.
    Thank you for the opportunity to comment. I urge you to continue funding technical assistance through the current system of funding Technical Assistance Centers. As the old saying goes, if it ain’t broke…
    The TA Centers are not broken. Please do not replace them.

    I have worked with the Kentucky Department of Education’s (KDE) Division of Learning Services (IDEA Part B) for 14 years. I began my employment with KDE as a staff attorney. After nine years, I became the division’s assistant director.

    I strongly support continued funding of OSEP’s Technical Assistance (TA) Centers (Option One), based in part on my experiences with the massive revisions that occured with IDEA and OSEP since the early 2000’s and my involvement with the TA centers. My first years at KDE were a period of significant changes with IDEA Part B, due in part to the 2004 IDEA Reauthorization. During this time, I was responsible for implementing KDE’s new self-assessment monitoring system required by OSEP. The self-assessment eventually became the State Performance Plan (SPP) which was required by the Reauthorization.

    To say this was a time of angst for State Educational Agencies (SEAs) is an understatement. It was a time of learning new ways of implementing IDEA, especially the change from monitoring for regulatory compliance to focusing on student outcomes. States learned about focusing on results for students with IEPs, including collecting and analyzing data, evaluating results, developing logic models, disproportionate representation, fiscal accountability, as well as proficiency for students with IEPs and their post school outcomes. In short, these were issues that we, at the state level, had never been required to examine.

    We did not have staff who were knowledgeable about most of these new areas. We did not have research departments as some larger states had, nor did we have staff who could be solely devoted to learning these new areas, as we were “paddling” as fast as we could. While OSEP staff consistently offered states much needed help and technical assistance during this time, they too were learning a whole new system and were stretched for time.

    Fortunately, OSEP had funded TA centers pursuant to Part D of the IDEA for many years. The TA centers were a lifeline to the SEAs. They had staff experienced in areas in which states were not knowledgeable. If the topics were new to a TA center, there was a network of centers that worked together and developed the needed assistance for the SEAs.

    Experiences of the past inform the present – and the future. There are new IDEA issues that constantly come up, which states are required to address. Unfortunately for SEAs, budgets have been slashed to the bone. The inability to hire new staff because of budget cuts and hiring freezes means that, in Kentucky, the number of KDE special education consultants is at an all-time low.

    This is a critical situation that is, by no means, a problem unique to Kentucky. It is simply impossible for SEAs to comply with IDEA as well as exercising their IDEA general supervision responsibilities over school districts without the help of technical assistance.

    Option 1 is the only option under which states can continue to receive high quality technical assistance which is critical to SEAs’ work. TA centers have kept talented staff who are experienced in every special education problem area. States are comfortable with TA center staff, since many TA providers know the states’ context as well as the states’ staff. There are no long periods of SEAs and TA center staff getting to know each other. The TA centers have hit the ground running.

    Kentucky has been especially fortunate to have a beneficial relationship with the IDEA Data Center (IDC) over the past 4½ years. IDC has helped Kentucky with a myriad of issues to build state staff capacity, ranging from training and coaching related to the federal reporting requirements, including the SPP and APR, to developing processes for the collection, validation, analysis, and submission of Section 616 and 618 IDEA data collections. IDC’s excellent resources on its web site builds states capacity, even when IDC is not working directly in the state.

    IDC has brought experts to KDE to provide training on privacy and confidentiality. It has helped us brainstorm areas in which KDE was considering changes to its current data governance and management. KDE relied on IDC staff to assist us in better understanding significant disproportionality and knowing the right questions to ask, when KDE was monitoring a large urban school district in which suspensions over 10 days for African American students with IEPs was an issue.

    IDC has provided training throughout the years in areas in which technical assistance is difficult to obtain. A great example of this is the IDC Interactive Institutes (regional data conferences). Over the past three years, IDC has convened institutes across the country in “all things data”, focused on topics related to improving IDEA data quality. The institutes have been universally praised, with participants saying it is the best conference they have ever attended. It would be impossible for states to duplicate this work on their own, or by contracting with individual TA providers

    KDE has also greatly benefited from other national TA centers. When KDE began contemplating its work for SPP Indicator 17 – the State Systemic Improvement Plan (SSIP) – we had the benefit of intensive technical assistance on implementation science from the State Implementation and Scaling-up of Evidence-based Practices (SISEP) Center. Implementation science is an evidence-based practice that is quite complex. Consultants from SISEP and its partner, the National Implementation Research Network (NIRN), have specialized in implementation science for many years. SISEP has used its expertise in assisting KDE in ground-breaking work.

    SISEP has provided on and off site technical assistance to KDE, local school districts and KDE’s regional cooperatives that are involved with our Indicator 17 work. SISEP has brought together other states and their partners which are involved in implementation science work, to learn from each other.

    As noted about IDC above, a network like SISEP cannot be duplicated by individual contractors or by individual states, both because of the complexity of implementation science (implementation science has its own language, its own system and its own tools to assist practitioners of the work) and the relationships SISEP has built over the years. If not for the assistance of SISEP, it would have been extremely difficult for KDE to scale-up its work under Indicator 17.

    My final “shout-out” is to the Center for IDEA Fiscal Reporting (CIFR). Several years ago, KDE found itself in a difficult situation involving Maintenance of State Financial Support (MFS), in which we were faced with a “payback” to OSEP of millions of IDEA dollars CIFR met with KDE numerous times and supported us during conference calls with OSEP.

    CIFR’s most intensive efforts involved work sessions in which their financial experts examined KDE expenditures. CIFR discovered areas in which KDE had expended state funds to support the provision of special education and related services to students with disabilities, which had not been reported in KDE’s MFS report to OSEP. OSEP found the recently discovered state expenditures to be allowable, thus relieving KDE from paying back any of the millions of dollars originally found to be owed to OSEP.

    This was not a small issue – thousands of Kentucky students with IEPs would have been affected, had CIFR not assisted KDE with its review. Other states have been assisted by CIFR in the same manner as KDE.

    To summarize, OSEP TA centers:
    · Have unmatched expertise with IDEA issues that often bedevil the SEAs;
    · Are a brick and mortar operation that will not disappear upon the relocation,
    retirement or death of a staff member;
    · Have built a network that collaborates and works together for the good of their
    states;
    · Have services that are free to the states, which is vitally important in the age of
    shrinking budgets; and,
    · Have “jobs alike” training and programs which are critical for practitioners.

    If the TA centers are replaced by private contractors or through extra funding to SEAs, OSEP and SEAs will have lost an irreplaceable resource. The TA centers have spent extensive amounts of time and effort in becoming experts in their fields, knowing their SEA clients and scaling-up their projects. If any other TA options listed are funded and replace the TA centers and then are not successful, SEAs will be in an untenable position.

    New TA systems cannot be built with a wave of a wand. The unprecedented work OSEP has been able to accomplish over the past years has been greatly aided by their partnership TA centers. If they disappear and are not successfully replaced, then who will assist the states — and OSEP?. It is frightening to imagine how SEAs would find expert resources needed for future new IDEA requirements.

    While the remaining options offered seem good in theory, they are not workable. As noted above, the option of providing funds to SEAs to contract for services is not practical. Contractors will typically not have the long standing expertise, experiences or relationships with states needed to provide intensive technical assistance.
    To refer to the examples above, finding contractors who have the understanding and expertise to consult with SEAs on IDEA data, disproportionate representation, the SPP/APR, implementation science and IDEA finance requirements would be difficult if not impossible. There would be no incentive for contractors to do the tasks TA centers currently do to increase state capacity, such as developing resources and websites, providing training to groups of states and creating networks of experts. Moreover, if there are qualified consultants available, it seems likely that “supply and demand” would keep SEAs from being able to afford intensive, long-term services.
    Executing contracts within state government is not a quick or easy task, due to the time needed to move the contracts through the state bureaucracy. In Kentucky, there is the added issue of the oversight exercised by the state legislature. Contracts are routinely “pulled” by legislative committees, which then question state agencies such as KDE about the necessity and purpose of the contract.
    Options three through five give several iterations of providing IDEA funds to SEAs directly for the purchase of technical assistance. Although the concept seems sound in theory, Kentucky would not benefit from this proposal in practice. The number of staff which can be hired within the Division of Learning Services and KDE is capped by the state. The limit on the number of employees does not allow Kentucky to hire additional staff, such as researchers or experienced practitioners, to fulfill the role of technical assistance providers.
    Thank you for the opportunity to comment. I urge you to continue funding technical assistance through the current system of funding Technical Assistance Centers. As the old saying goes, if it ain’t broke…
    The TA Centers are not broken. Please do not replace them.

  16. As the Special Education Director at the Alabama State Department of Education, I encourage the Department to pursue Option 1, continue funding the national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B responsibilities.

    Data collected pursuant to IDEA must be timely, valid, and reliable and reported in such a manner as to ensure that all students with disabilities are receiving FAPE. Alabama has received valuable and timely assistance from these TA Centers to help us reach our goals, particularly the assistance from the DaSY Center, the IDC, CIFR, and NCEO Centers. The PSC has been a constant partner with the state team responsible for ensuring the accuracy of data submissions and providing essential services to all states.

    Moreover, changing the funding structure of the Centers would become a barrier to the efficient achievement of state goals due to the lack of state resources, as well as the time necessary to navigate Federal and state rules and regulations related to the procurement of a vendor to provide the technical assistance. Additionally, personnel providing expertise from the Centers have been “vetted” as experts, so that states are assured of receiving reliably accurate information. An unintended consequence of states securing their own experts to provide the assistance currently being provided by the Centers may be a patchwork of providers who may not necessarily have access to the most current and accurate information.

    Funding inequities among states may further imperil equal access to technical assistance that is sufficient to meet state needs, yet Part B reporting requirements remain the same across all states. Further, the State Systemic Improvement Plan (SSIP) requirements further underscore the need to continue access to an array of technical assistance resources as states strive to increase results for students with disabilities. An inability to access technical assistance could not only jeopardize the progress already underway in many states but also threaten essential compliance with the requirements of the law.

    We respectfully request that our input be thoughtfully considered. These decisions will impact the lives and futures of students with disabilities and their families living within Alabama for many years to come.

  17. Washington State Part B supports Option 1 to continue to fund national TA Centers to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    OSEP-funded TA Centers currently provide direct support, tools and resources to states, and serve as hubs of technical expertise. These TA centers are a key resource in an ever changing regulatory environment, particularly when coupled with staff turnover at the state-level. Federal special education data reporting requirements are continually changing and expanding. This continuous change paired with state staff turnover makes it imperative to have consistent technical assistance that is available to states without going through a procurement process and without states having to worry about inconsistencies between various technical assistance providers.

    To address the directed questions, states experience ongoing challenges in interpreting and implementing changes in federal requirements. Technical assistance is needed across the entire spectrum of the data cycle: collection, reporting, analysis, improvement, and evaluation.

    Products or services that Washington state staff have used and found beneficial include, but are not limited to:
    • National face-to-face meetings for state staff (NCSI, ECTA, IDC)
    • NCSI technical assistance, specifically with the SSIP.
    • ECTA technical assistance on
    o early childhood outcomes,
    o DEC recommended practices
    o SSIP and early childhood SPP Indicators
    • CIFR’s technical assistance on MOE/CEIS
    • CIFR’s regional conference calls
    • IDC’s resources/technical assistance on:
    o process documentation,
    o EdFacts Pre-submission Tools
    o webinars and tool kits on all SPP indicators including the SSIP
    o significant disproportionality, including Success Gaps Tool
    • CIID’s Generate tool

    Suggestions for improvement of the current TA Center system include the following:
    • Currently, there is overlap in content and staff between the various TA Centers. There are multiple tools that address basic data processes including data governance, system frameworks, documentation protocols, etc. This can lead to confusion – states do not always know which center to approach with a question or where to go to find relevant content. The overlap could be greatly reduced by combining some of the TA Centers, so that a smaller number of TA Centers have a broader, clearer focus. This could also help reduce the number of TA Center points of contacts that states have, as well as reduce a perceived feeling of competition between TA Centers.

  18. I serve as the state Director for Special Education at the Kentucky Department of Education (KDE). I have been at the KDE for eight years and spent the past three in the role of state director.

    I strongly believe USED should continue with Option 1, funding national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    State Education Agencies (SEA) are charged with implementation of IDEA, which includes the reporting of data for Child Count and the annual performance reports. The data collected must be valid and reliable and reported in such a manner as to be used in making important policy implementation decisions to ensure that all students with disabilities are receiving FAPE.

    SEAs must also meet the fiscal requirements of the IDEA with respect to maintaining state financial support as well as the general oversight responsibilities for ensuring LEAs meet the Maintenance of Effort (MOE) requirements.

    USED’s Office of Special Education Programs (OSEP) funded TA centers have provided tremendous assistance in helping states reach these goals and requirements.

    When I initially took the role of state director, I was faced with the issues that plague most states: budget constraints, too few staff, high staff turnover rates and lack of staff experience.

    I quickly turned to the IDEA Data Center (IDC) in search of assistance. Thanks to a long standing relationship, IDC was able to immediately jump in and provide much needed assistance in many areas. IDC was an instrumental partner in assisting KDE to build state staff capacity ranging from training and coaching related to the federal reporting requirements, including the SPP and APR, to developing processes for the collection, validation, analysis, and submission of Section 616 and 618 IDEA data collections. IDC has brought experts to KDE to provide training on privacy and confidentiality as well as helping us brainstorm areas in which KDE was considering changes in its current data governance and management. KDE relied on IDC staff to assist us in better understanding significant disproportionality and knowing the right questions to ask, when monitoring local education agencies (LEAs).

    State Maintenance of Financial Support (MFS) was another area in which I needed immediate support. Kentucky was facing a deficit in its MFS that would have required a considerable return of funds to USED. With the assistance of Center for IDEA Fiscal Reporting (CIFR), we were able to identify eligible state expenditures that resulted in meeting this MFS requirement and averting the payback of funds. Perhaps the most significant point to be made about this is that without the help of CIFR, thousands of students with IEPs would have suffered as a result of the loss of funds.

    The Center for the Integration of IDEA Data (CIID) has the Generate Tool that works in conjunction with the state’s student information system to produce quality EDFacts files. Because of the intricacy in producing the EDFacts files in the formats they are required, this tool holds the potential to free up time and resources of SEA staff in meeting the section 618 data requirements of the IDEA. Kentucky has begun the dialogue with CIID to investigate the potential of incorporating the Generate Tool into its processes and we are excited about this opportunity.

    The State Implementation and Scaling-up of Evidence-based Practices (SISEP) Center has provided KDE with ongoing support for several years in its work for Indicator 17, the State Systemic Improvement Plan (SSIP). Implementation science is an evidence-based practice that is quite complex, with SISEP and its partner, the National Implementation Research Network (NIRN), assisting states with ground-breaking work. Through the support and coaching of SISEP, we are not only building capacity within KDE but across the state as well through Kentucky’s special education divisions of the regional cooperatives which are closely involved with this work.

    The current structure of the TA Centers provide states with a level of trust and confidence. TA staff are extremely knowledgeable and typically have experience working in SEAs. Their connection with OSEP provides the conduit for states to stay “in the know” without bogging down OSEP with questions and concerns from states. It is reassuring to receive technical assistance from centers that are governed by OSEP, which is the authoritative source for IDEA. It would be impossible to replicate this type of support from a private contractor or other means.

    Losing the TA Centers would not only be detrimental to the SEA but the fallout would have lasting negative effects on regional cooperatives, schools and districts, and most importantly students with disabilities. The network provided by the TA Centers is irreplaceable – the system, and the relationships, are already built and being implemented. The positive effects Kentucky has seen as a result of the support of OSEP funded TA Centers is beyond measure. The TA Centers provide expertise and historical perspectives that states simply cannot find elsewhere. As a state director, I hate to imagine a future without this level of trust and support.

    • NASDSE and the Illinois State Board of Education (ISBE) believes the Department should continue with Option 1, funding national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

      Our staff is charged with implementation of IDEA, which includes the reporting of data for Child Count and the annual performance reports The data collected must be valid and reliable and reported in such a manner as to be used in making important policy implementation decisions to ensure that all students with disabilities are receiving FAPE. The TA centers that are funded under Section 616 of the IDEA have provided tremendous assistance in helping states reach these goals.

      Changing the funding or structure of TA is counterproductive to achieving these goals, as it assumes the states have the resources and time to address data issues as they arise—timely support is key to the ability to provide quality data. The TA centers have the knowledge and information to facilitate states learning from one another. If instead, OSEP chooses to give these funds directly to the states, there will be no opportunity for cross-state learning nor will the states be in a position to more clearly see how they can improve the quality of their data and reporting. Additionally, if changed, the funding structure would not provide an equitable distribution of dollars to every state. Under the proposed approach, smaller states would receive fewer funds, yet their reporting requirements and obstacles to reporting are the same as larger states. Furthermore, pushing funding down to the LEA level would result in even more inequality, with larger school districts receiving more funding, leaving little for smaller districts. An inability to access technical assistance in a timely manner could jeopardize the ability of the states to fulfill the requirements of the law.

      While we recognize the effort to provide the states with flexibility that will allow them to best meet their individual needs, this is one area in which federal funding and expertise is desired.

      Changing the funding structure does more than change how funds are distributed. It waters down the expertise available to states. The TA centers serve a vital function by providing their expertise to states and assisting them in obtaining the highest quality data possible. Without their assistance, the ability to implement research-based and data informed changes to our K-12 system would be challenging.

      We implore the Department to carefully consider the states’ input on this proposal as the state directors are the direct recipients of this support. As the intended recipients of the use of these funds, the state directors emphatically reject any proposals to revamp how these funds are distributed so that we can continue to provide the best possible strategies to ensure positive outcomes for all students, including students with disabilities.

  19. I write on behalf of the Conference of Educational Administrators of Schools and Programs for the Deaf (CEASD). CEASD supports Option 1 for the reasons outlined in the comments submitted by the Consortium for Citizens with Disabilities, of which CEASD is a member.

    On a related topic, CEASD urges the Department to encourage states to disaggregate outcomes data based on the disability categories named in the Individuals with Disabilities Education Act. Currently it is not possible to obtain a national picture of academic performance of deaf and hard of hearing students (or students in any other of the categories) served under IDEA. Outcomes are viewed across the board, thus masking the performance of students in smaller, “low incidence” categories.

    The Part B Indicators are intended to capture (among other things) whether students are receiving a Free Appropriate Public Education (FAPE) in the Least Restrictive Environment (LRE). Data based on disability category are reported on the amount of time students spend in the “regular” class or in specialized schools, but this number alone says nothing about whether the student is receiving FAPE in the LRE. Only by looking at student needs, services, and outcomes is it possible to confirm whether a student is receiving FAPE in the LRE. While many mistakenly believe the terms “regular” class and LRE are synonymous, in fact LRE is an individualized determination for each student.

    In closing, CEASD supports Option 1 and urges the Department to encourage states to disaggregate outcomes data based on the disability categories named in the Individuals with Disabilities Education Act.

    Thank you for the opportunity to comment.

    Barbara Raimondo
    Executive Director

  20. I write on behalf of the American Speech-Language-Hearing Association (ASHA) to comment on how best to provide TA to states on collecting and reporting data required under Part B, Section 618 and Section 616, of IDEA, including input on the most effective and efficient method of funding this TA.

    ASHA is the national professional, scientific, and credentialing association for 198,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. Audiologists specialize in preventing and assessing hearing and balance disorders as well as providing audiologic treatment and devices (i.e., hearing aids). Speech-language pathologists (SLPs) identify, assess, and treat speech and language problems, including swallowing disorders. More than half of SLPs are employed in educational settings. The services provided by our members help to ensure students receive a free appropriate public education (FAPE).

    ASHA strongly supports Option #1 for continuing to fund national TA Centers using funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618. The TA centers are a cornerstone for a number of states and for improved outcomes for students with special needs. National TA Centers are instrumental in providing high-quality assistance and much needed infrastructure and services to SEAs and LAs to comply with the IDEA data collection requirement of the law. States rely on the data collected to determine significant disproportionality under IDEA. In addition, data on the prevalence of students with hearing, speech, and language impairments provide national trends information that are used by various stakeholders, including professional associations such as ASHA. It is imperative that the Department continue to fund national TA Centers so states can provide equitable opportunities, services, and adequate resources to improve outcomes for infants, toddlers, children, and youth with disabilities.

    ASHA does not support Option #2 because allowing SEAs and LAs to apply directly would diminish the state’s ability to access high-quality data provided by national TA Centers. The national TA Centers provide states economies of scale by collecting data, doing research, and tracking national trends.

    ASHA believes that Option #3 could further reduce the supports that students with disabilities are receiving by lumping it together with the IDEA Part B formula state grants, especially for states that are already struggling to manage resources with underfunding for IDEA. Further, we question whether the U.S. Secretary of Education has the authority to implement Options 3, 4, or 5 as suggested by OSERS because we believe those options would require statutory changes to IDEA. Therefore, those options do not appear to be viable at this time.

    Thank you for the opportunity to provide these comments.

    Elise Davis-McFarland, PhD, CCC-SLP
    2018 ASHA President

  21. The Special Education Data Manager Affinity Group (SEDMAG) is a nationwide network of Part B state data managers affiliated with the National Association of State Directors of Special Education. SEDMAG supports Option 1 to continue to fund national TA Centers to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    OSEP-funded TA Centers currently provide direct support, tools and resources to states, and serve as hubs of technical expertise. These TA centers are a key resource in an ever changing regulatory environment, particularly when coupled with staff turnover at the state-level. Federal special education data reporting requirements are continually changing and expanding. This continuous change paired with state staff turnover makes it imperative to have consistent technical assistance that is available to states without going through a procurement process and without states having to worry about inconsistencies between various technical assistance providers.

    To address the directed questions, states experience ongoing challenges in interpreting and implementing changes in federal requirements. Also, using data in meaningful ways, both at the state and local levels, is an essential function that states struggle with. Technical assistance is needed across the entire spectrum of the data cycle: collection, reporting, analysis, improvement, and evaluation.

    Products or services that states have used and found beneficial include, but are not limited to:
    • National face-to-face meetings for state staff
    • CIFR’s technical assistance with allocations process
    • CIFR’s technical assistance on MOE/CEIS
    • CIFR’s regional conference calls
    • IDC’s various resources on process documentation
    • IDC’s resources for new Data Managers
    • IDC’s resources on significant disproportionality, including Success Gaps Tool
    • IDC’s resources on Indicator 4/Discipline
    • CIID’s Generate tool

    Suggestions for improvement of the current TA Center system include the following:
    • Currently, there is overlap in content and staff between the various TA Centers. There are multiple tools that address basic data processes including data governance, system frameworks, documentation protocols, data visualization, etc. This can lead to confusion – states do not always know which center to approach with a question or where to go to find relevant content. The overlap could be greatly reduced by combining some of the TA Centers, so that a smaller number of TA Centers have a broader, clearer focus. This could also help reduce the number of TA Center points of contacts that states have, as well as reduce a perceived feeling of competition between TA Centers.
    • A TA Center should provide more intensive, direct support to new Data Managers. There is a relatively high attrition rate for special education Data Managers. Each year, a new cohort needs the fundamental knowledge and skills to carry out this complex work with fidelity. Currently, no single TA Center fills this core need. The TA Center should work with Data Managers from other states or by having TA center staff who have recent state experience to ensure the support is relevant in the current landscape.
    • In outlining the charge for any TA Centers, the constituency and roles need to be well defined. For example, if Data Managers are a primary audience for a center, then Data Managers should be surveyed about their technical assistance needs.
    • The TA Center(s) needs to go beyond the basic requirements of collecting/reporting data and making allocations. Technical assistance needs to address the use of data in improving outcomes for students.
    • The TA Center(s) should expand the facilitation of state meetings (Data, Fiscal, etc.) where states are able to connect with one another as content experts along with TA Center staff. Data Managers consistently report that the peer-to-peer learning and networking opportunities at these meetings provide the most direct benefit to their work.

  22. As an Education Associate at the Delaware Department of Education, I support the continued funding of the National Technical Assistance Centers as described in option #1. With the help of our TA providers at IDC, Delaware has held several “Data Retreats” throughout the year. IDC TA providers have facilitated the work of bringing numerous workgroups within the Delaware Department of Education together to discuss and document data collection and processes which as been invaluable. The TA providers are extremely knowledgeable, responsive, and have always been readily available to answer questions. I cannot express just how important the TA Centers are to the work that we do for our children!

  23. The Michigan Department of Education Office of Special Education is in full support of the continuation of the funding for national TA Centers. Michigan relies on and is benefitting from high quality technical assistance available through these national supports to States. The vast support in addressing the needs each state has requires expertise, a solid framework and assistance to increase and improve a state’s capacity to meet the myriad requirements of the federal IDEA.
    The Michigan Department of Education is addressing large system change across our state as it pertains to creating an aligned and coordinated system between our 56 LEAs and nearly 900-member districts. This type of change needs to be focused on evidence-based practices implemented with fidelity to ensure we are positively impacting improved outcomes for all students, including students with disabilities. Support from our partners at these national TA Centers is critical to our ability to address this transformative change. The TA staff are highly knowledgeable and skillful as well as prepared to provide the needed assistance unique to the individual States.
    Changing the funding structure to will only compromise the State’s ability to effectively implement the federal requirements at every level of our educational system. By shifting the work of these centers to states, we will experience a reduced consistency of practices across our country which will result in less common understanding and coordination of responses needed to meet requirements. States are vulnerable in losing the benefit of a national perspective regarding best practice, as well as a loss in national coordination of cross-state networks.
    The Michigan Department of Education supports Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i)(Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Section 616 and 618.

  24. These comments are provided on behalf of the Division for Early Childhood (DEC) of the Council for Exceptional Children. The Division for Early Childhood (DEC) of the Council for Exceptional Children is the largest membership organization focused solely on the development and education of young children (ages birth–8) with or at risk for disabilities and other special needs and their families.

    DEC feels strongly that the Department should continue with Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618;
    We agree with the comments from both NASDSE and ITCA, the organizations representing the state recipients of these TA efforts, valuing the expertise and tools made available by the collaborative efforts of the national centers. We also are concerned about the continued availability of TA for Part C if the current TA structure is changed.

    The current TA structure has proven to be an effective and efficient use of available TA funds. The TA centers, as currently funded, have provided tremendous assistance to help ensure that the data collected are valid and reliable and reported in a manner that enables states to make important policy decisions to ensure that states and locals meet requirements under the Individuals with disabilities Education Act (IDEA). The TA centers have the expertise, knowledge and information to facilitate states cross-state learning from one another.

    Giving the funds to states to purchase TA is not an effective option based on varying difficulties in states with timely procurement activities, priority setting, availability of adequate TA resources and duplication of efforts and redundancy in product development and other work currently made more efficient through funding national centers.

    Thank you for the opportunity to submit comments. In summary, we strongly support Option1 to maintain the current TA structure. DEC is available and willing to provide any additional information that may be needed. Feel free to contact us if we may be of further assistance.

  25. As the Chair of the Hawaii Special Education Advisory Council (SEAC) we appreciate this opportunity to express our preference for maintaining Option 1—the continuation of the National Technical Assistance Centers. Hawaii’s public school students with disabilities represent a unique mix of ethnicities and cultures. Our state is also geographically isolated and unable to benefit from the cross-pollination of ideas and information that occurs on the Mainland. SEAC and the Hawaii Department of Education have benefited greatly from the quality, diversity and reliability of the data and technical assistance provided by the Centers, as well as the continuity of support by personnel familiar with Hawaii’s unique challenges.

    At the invitation of our Special Education Director, SEAC has grown its expertise by interactions with various Center staff on the following issues:
    Analysis of APR data and improvement activities, recommending significant disproportionality risk ratios, enhancing our Leading by Convening processes, and understanding Hawaii’s due process activity in the context of national trends and norms. We also appreciate the ability to freely access and utilize resources developed by the Centers, such as “Building Stakeholder Knowledge About Data” on the DaSy website.

  26. The following comments are submitted on behalf of the Council for Exceptional Children (CEC), a professional association of educators dedicated to advancing the educational success of children and youth with exceptionalities that accomplishes its mission through advocacy, standards, and professional development.

    CEC appreciates the opportunity to comment on the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) questions on how to best provide technical assistance (TA) to states on the collection and reporting of data required under Section 616 and 618 (which apply to Part B and Part C), and the most effective and efficient method of funding this effort.

    CEC strongly supports Option 1, with continued funding for the existing national TA centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    Reasons for CEC’s support of Option 1 are presented in the following comments:

    • State IDEA Part B and C State Directors through their professional associations (NASDSE and ITCA) have recommended Option 1.

    • The current national TA centers that focus on collecting and reporting data are valued by the field for their consistent expert knowledge and leadership to state teams to ensure that states and locals meet the requirements under the Individuals with Disabilities Education ACT (IDEA). The tools and direct support made available through general, targeted and intensive technical assistance assist states and locals in understanding the collection, reporting and use of high quality data. This data informs states in their evidence-based policy and practice decisions, resulting in state and local program improvement and greater outcomes for children and their families.

    • Dividing available funds across all the SEAs and Part C lead agencies would result in inadequate resources for a state to purchase all the TA needed individually, instead of the cost efficiency of a national TA center. In addition, a state funded structure would not provide an equitable distribution of dollars to every state and local.

    CEC appreciates the opportunity to provide comments on the use of Part B program funds for technical assistance to states on IDEA data collection.

  27. 1. What challenges does your State face in collecting, analyzing, reporting, and using IDEA Part B and Part C data required under IDEA Sections 616 and 618?
    a) After collecting this data for several years, Louisiana has, in place, processes to collect, analyze and report 618 data—we experience no current challenges in this area.
    2. Are there other investments that the Department should pursue to meet States’ IDEA data TA needs, and how should these investments be funded?
    a) Due to the level of involvement states require for the development, implementation and evaluation of the SSIP, TA investments should focus primarily in these areas with individualized, timely, need-based TA. Currently professional development and data management specific to implementation fidelity are high priorities across all states.
    b) Fund centers with clearly discrete responsibilities to avoid duplication of effort.
    c) Offer states opportunity for a TA “team” who work together on all state activities rather than pulling in support on “as needed” basis. Yes, the state has a contact person with each center, but when that person has not been involved all along, it can be more work to loop them in later than it is to have them on board throughout.
    3. What do you believe would be the potential benefits or limitations of the following TA funding options:
    a) The Department continues to reserve funds under IDEA section 616(i) (Part B) to fund national TA centers to support the IDEA Part B and C State Data Collection Program;
    Option a this is the best option for TA support for the following reasons:
    1. greater access to support—more resources are available to states when funded nationally than if a state used resources only allocated to itself. In the latter, the support would be more limited in scope and require states to conduct the research to look for resources.
    2. the advantage of knowledge available at the national level across states resulting in better information sharing when national providers understand the work going on in the states
    3. Funding national TA centers has afforded opportunities for states to meet with each other, whereas individually funded states would not have this option. For example—in the individually funded option, a state would have their allocation, but in times where they are prohibited from travelling may not be able to use their own resources to travel to meet with another state. In the current model, since travel is available to states to meet more states can access the interaction with other states.

  28. NDSC is a member-sustained, nonprofit organization, which works to promote the interests of people with Down syndrome and their families through advocacy, public awareness, and information. We appreciate the opportunity to provide input on the blog post from the Office of Special Education and Rehabilitative Services (OSERS) regarding funding for Technical Assistance (TA) to states on collecting and reporting data required under Sections 618 and 616 of the Individuals with Disabilities Education Act (IDEA).

    In its blog post OSERS proposed four options for providing TA to states. For the reasons stated below, NDSC feels strongly that the U.S. Department of Education (ED) should continue with Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618. All the other options would reduce or remove funding from critically important national TA centers and send it to the states where it would not be used as effectively or efficiently. The National Association of State Directors of Special Education (NASDSE) stated in its comments that changing the funding or structure of TA is counterproductive to achieving their members goals, as it assumes the states have the resources and time to address data issues as they arise. NASDSE’s comments also express how much their members value the work of the national TA Centers. NDSC agrees.

    • The TA centers, as currently funded, have provided tremendous assistance to help ensure that the data collected is valid and reliable and reported in a manner that enables states to make important policy decisions so that states and local education agencies meet requirements under IDEA.

    • The TA centers have the expert knowledge and information to facilitate states learning from one another, which is critical when resources are scarce and the IDEA is not fully funded.

    • Currently, the TA centers are funded at approximately $21 million, therefore dividing and distributing a portion to each state using the Section 611 formula will result in the per state funding being too small to have much impact. Additionally, this option would eliminate national Part C data technical assistance since these funds would be reallocated to Part B grants, only.

    • A change in the funding structure would result in an inequitable distributions of funds. Smaller states would receive fewer dollars, although their oversight, reporting and other responsibilities are the same as larger states.

    • Giving the funds to states to purchase TA would mean additional overhead in each state as states will have to make awards to vendors who would provide the TA.

    • Even if the states want to band together to purchase TA it would be very complicated with each state having its own procedures, statutes, lawyers, etc.

    • The model of each state (or even groups of states) providing TA on data collection would result in redundancy in product development and other work across the states that National Centers generally minimize.

    The critically important support provided to states by the Part B funded TA Centers can be exemplified by three projects at the National Center on Educational Outcomes (NCEO). Through its efforts supported by Part B set-aside funds for data collection requirements, NCEO is:

    1. Providing support for a Community of Practice of 30 states with 69 state personnel on data collection and topics related to their implementation of the 1% cap on participation in alternate assessments based on alternate achievement standards. The number of states exceeding the cap makes it clear that they need this TA from NCEO.
    2. Developing intensive technical assistance plans with states on their State-Identified Measurable Results (SIMRs).
    3. Working with States to support their understanding of how to effectively use local assessment data within a larger state assessment and accountability system.

    NDSC firmly believes that in addition to the financial, logistical and other challenges described in the bullets above if Option 1 is not continued, OSEP’s monitoring, technical assistance, and accountability for implementing IDEA would be weakened as the quality of data collected and reported diminishes. Additionally, we fear that a reduced or weakened Federal role likely means lower compliance with the IDEA and reduced commitment to the education of students served under the IDEA. NDSC strongly urges ED to continue with Option 1.

  29. The Learning Disabilities Association of America (LDA) appreciates the opportunity to offer comments regarding the best funding mechanism to provide technical assistance to states on data collection and reporting under the Individuals with Disabilities Education Act (IDEA).

    LDA – a national volunteer organization representing individuals with learning disabilities, their families, and the professionals who serve them – has worked for more than 40 years to ensure children with specific learning disabilities are properly identified and receive appropriate services to enable them to fully benefit from these educational opportunities, graduate from high school, and meet their postsecondary goals.

    OSERS has offered four options to provide TA to states on the IDEA data collection requirements. LDA supports continuation of Option 1 — funding national technical assistance centers through reservation of funds by the U.S. Department of Education under IDEA, Part B, Sect. 616(i).

    As currently constituted, the TA centers provide great assistance to states in ensuring data collected are reliable and valid and reported in a usable fashion. The purposes of these data are to shine a light on implementation of the IDEA and inform good policies that result in eligible students have successful school experiences. The current TA system is meeting these goals.

    The other options will result in an unequal system of technical assistance, favoring some states over others. Option 2 calls for states to apply for funds, requiring staff time and resources to engage in the application process and with funds only going to those states able to invest in the application process. In addition, not all states will be able to purchase the kind of expert technical assistance they now receive from the national centers.

    The other options are equally untenable. Moving funds to Part B state grants again puts the onus on each state to find its own technical assistance, and the amount each state would receive will not buy what states need. Most important, the economy of scale achieved by having national centers means federal dollars go further, serve states equitably, and eliminate redundancy in developing resources and providing services.

    LDA strongly recommends OSERS retain the current system of providing technical assistance on data collection and reporting to maintain data quality, resulting in better services to children and youth with disabilities.

  30. I am a former 619 coordinator. The support, help, tools, and resources available through DaSy, ECTA, and IDC equipped me with the needed skills as a 619 coordinator. These resources are invaluable to the success of our state being able to develop, grow, and implement services for preschool children with disabilities.

    These centers have provided supports through cohorts to help us review our data and make changes based on the data. They have provided training for our LEA staff regarding data. The communities of practice available connect us with other states so we can learn and grow based on others successes. The TA centers are able to find additional resources and provide ongoing technical assistance. They are quick to respond and provide the tools leaders need.

    Based on the experiences described above, I believe Option #1 is the best method for providing continued support to states.

  31. As the IDEA Part B Data Manager for the Maine Department of Education, I am in full support of the continuation of regional TA centers (Option 1). In my work, I have turned to the TA centers repeatedly for guidance and suggestions regarding data collection protocols, quality assurance, analysis, data presentation, stakeholder engagement, and other activities across virtually all IDEA collections and reports. The assistance I’ve received has been exemplary and timely, and I fully support the continuation of their present status.

  32. The Hawaii Department of Education supports the continuation of the national TA Centers as they have been essential for our state. Staffing transitions and data mapping are examples of recent challenges that the TA Centers have successfully helped Hawaii address. TA support from the Centers has substantially assisted our new staff to develop knowledge and confidence while preparing the data for submission. Given the tight timelines and the high stakes nature of the reporting, the TA Center support was invaluable. The TA staff have been very knowledgeable and skillful when providing TA focused at our specific level of need as our knowledge has developed. We have not yet encountered a situation for which a TA Center or a combination of TA Centers was not prepared to assist.

    The three funding options presented in Question 4 vary on the continuum of flexibility to standardization. Their benefits and limitations reflect the burden placed on States, timely access to technical assistance (TA), and confidence in the quality of the TA. Option A has the lowest burden on States. The TA is quickly available as no State-level procurement is required. The Centers are providers vetted by OSEP, so the confidence in the accuracy of their TA is high. The shared knowledge across the Centers and the “no cost to State” TA opportunities encourage participation by State staff. Options B and C increase the burden on States through the additional application and procurement processes that would potentially delay the onset of TA. Those options would decrease the overall confidence in the quality of the TA as well as introduce access barriers to reliable information.

  33. The following comments are provided on behalf of the IDEA Infant Toddler Coordinators Association (ITCA), the national organization that represents states and other jurisdictions implementing the Individuals with Disabilities Education Act (IDEA) Part C for infants and toddlers with and at risk for developmental delays and disabilities and their families.

    ITCA appreciates the opportunity to comment on the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) questions on how to best provide technical assistance (TA) to states on the collection and reporting of data required under Section 616 and 618 (which apply to Part B and Part C), and the most effective and efficient method of funding this effort.

    The ITCA membership utilizes the high quality technical assistance that is currently being made available through these national centers. When surveyed regarding these OSERS’ questions and options for future TA, our members stated the value of the current TA for Part C state systems and expressed concern about the continued availability of TA for Part C if the current TA structure is changed.

    Therefore, ITCA strongly supports Option 1, with continued funding for the existing national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618. We offer the following comments based on our survey of ITCA state members regarding this topic.

    Value of Present TA System Structure:
    The current TA structure provides consistent national expertise regarding the implementation of IDEA Part C data requirements. The information, tools and direct support made available through general, targeted and intensive technical assistance by the National TA centers have been invaluable to lead agencies as they help state and local Part C staff in understanding the collection, reporting and use of high quality data. This knowledge and these skills are essential to using data to improve outcomes for children and families as well as to facilitate state and local program improvement. This use of data is especially critical to states as the State Systemic Improvement Plan (SSIP) requires an evaluation plan that measures and analyzes child outcome data.

    ITCA members reported the TA centers currently:
    • Connect states that are working on similar initiatives (e, g, states utilizing electronic IFSPs or states linking data) to share information and resources;
    • Create and facilitate multiple in-person and virtual cross-state opportunities to allow states to work on targeted topics as needed;
    • Assist in building state data-related infrastructure including assisting in the planning for and design of business rules and data specifications for new state data systems; and
    • Provide a wide variety of assistance that can meet the individual needs of states with TA methods that are flexible in responding to state priorities, resources and capacity.

    Challenges States Currently Face:
    ITCA members reported a number of ongoing challenges related to the collection and use of high-quality data. These include:
    • Significant staff turnover at the state level, particularly the Part C Coordinator and data manager. This results in the need for ongoing support to provide knowledge and training for these individuals in understanding the complexities of the data, ensuring its quality and building skills in utilizing the data for continuous improvement;
    • Need for additional support and resources to assist in the design of data analyses and generation of useful state and provider level reports;
    • Lack of available resources at state and local level to develop and run reports; and to manipulate and analyze available data for stakeholders;
    • Planning strategically with all stakeholders for enhanced data work including creating support from agency leadership;
    • Efforts to explore and begin linking data with other programs and systems;
    • Need for a new and/or enhanced state data system with capabilities needed for current priorities including Results Driven Accountability (RDA) and need to create a web-based financial reporting database; and
    • Ensuring the continued high quality of all data.

    Potential Limitations of Changes to the TA Structure:
    ITCA members reported concern if the current structure is changed, there will not be sufficient resources for TA for Part C. In fact, based on the possible options, there may be no TA available for Part C lead agencies at all. Specific concerns mentioned include:
    • Dividing available funds across all the SEAs and lead agencies would result in inadequate resources for a state to purchase all the TA needed individually instead of the cost efficiency of a national center that can create tools and provide expertise that is available nationwide; and
    • States may not be able to obtain necessary technical assistance with data needs for a number of reasons including:
    o Securing individual TA can be more expensive requiring additional state resources to contract with outside providers;
    o Need for state staff to manage and monitoring these TA contracts;
    o Need for a timely procurement process which is not always possible;
    o Depending on state priorities, states may not invest in data capacity resulting in a possible decrease in quality data, state data capacity and use;
    o Funds can be underspent and timing of grant dollars availability may be inconsistent with state timelines; and
    o Adds more paperwork and process to access and use the funds.

    Possible Additional National Technical Assistance:
    ITCA members suggested the following possibilities for Part C TA for consideration:
    • Analyze gaps and overlaps in the current Data TA Center structures and consider consolidating or clarifying scope to avoid duplication while continuing to comprehensively address states’ IDEA data needs;
    • While not possible under this fiscal authority, find and target funds for state data infrastructure investments (e.g., new or enhanced data systems, web-based financial database, monitoring database, etc.) that may be utilized by Part C states to improve capacity;
    • Expand the current Center for IDEA Fiscal Reporting (CIFR) to include technical assistance for Part C systems;
    • Consider reinstituting the former General Supervision Enhancement Grant (GSEG) that would be available to access by Part C programs as well as Part B/619; and
    • Consider a designated TA person for each State from one of the centers to support all areas of TA to help states navigate the overlap of TA centers.

    In summary, ITCA asks the Department to carefully consider the states’ input on these proposals. As the intended recipients of the use of these funds, we strongly support Option 1 to continue the current national TA structure. The current TA structure has proven to be an effective and efficient use of available TA funds.

    Thank you for opportunity to submit comments to these proposed changes. As always, ITCA is available and willing to provide any additional information or clarification that may be needed. Feel free to contact us by email at ideaitca@aol.com if we may be of further assistance.

    Sincerely,
    Pam Thomas, ITCA President
    Terri Enters, ITCA Vice President

  34. The Idaho State Department of Education-Special Education Division is in support of Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618;

    In January of 2015, I became Idaho’s State Special Education Director and since that time I have relied heavily on a number of the TA centers. In fact, I would not still be in this position without the support of the various TA centers. Not only was I new in my postion 3 years ago, but I had to hire a number of folks for critical positions. For example, I needed a Data manager, Fiscal Coordinator, SSIP/monitoring coordinator to name just a few. With essentially a new team, we quickly reached out for support from the various experts associated with the TA centers. Below are just some of the centers/resources we relied on:

    IDC: assisted in supporting my new data manager–very responsive, supportive and most importantly gave us access to tools/resources that we have used to improve our practices. We utilized many of the tools shared at the IDC Interactive Insitute.
    CIFR: Spported my new staff through the community of practice calls, very quick in responding to questions, have provided high quality and useful tools that we are currently using. We found the fiscal forum to be a really good use of our time
    NCSI: Very vaulable in supporting our SSIP work, and monitoring. They are very responsive to meeting the unique needs ofour state.

    At first, accessing the various TA centers was confusing and a bit overwhelming, but not any more–collectively they do amazing work and Idaho, being a rural state we do not have a lot of resources to tap–we NEED the TA centers to assist us in improving practices, compliance with federal regulations and most importantly to assist us in improving results for student with disabilities.

  35. The Indiana Department of Education’s Office of Special Education recommends the continued funding of the national technical assistance (TA) centers for the reporting and use of data required by the Individuals with Disabilities Education Act (IDEA).

    The national technical assistance centers provide an important resource for the effective dissemination and implementation of existing and new federal rules in relation to data. The opportunities for collaboration and instruction that are provided by the technical assistance centers enhances OSE’s ability to submit timely and accurate data to the United States Department of Education (USED).

    Technical assistance is most helpful in assisting new staff in the use of data to effectively implement programs directly mandated by USED as well as carrying out their monitoring and fiscal responsibilities. Efficiency and effective implementation would be much more difficult without a technical assistance resource.

    The various purposes served by the technical assistance centers may be combined and streamlined into larger, more streamlined national technical assistance, with clear pathways for states to access specific resources.

  36. As the State Director of Special Services for the Maine Department of Education, I am in full support of the continuation of regional TA centers (Option 1). Maine has benefitted greatly from the expertise and timely assistance of the data centers. As a small state, we would not have sufficient resources to independently obtain quality technical assistance to ensure the valid and reliable reporting of data. The TA centers have provided a critical resource on numerous issues. Our work would be much more difficult without their expertise and knowledge. We appreciate the intent to provide states with more flexibility in obtaining technical assistance. However, for small states it will most likely limit our options and the quality of assistance we are able to obtain. We have been well served by the data centers and support the continuation of their present status.

  37. As the State Director for Montana’s IDEA Part B program, I would wholeheartedly encourage the Department to continue to fund the national TA centers with IDEA set-aside funds (Option 1). Montana has worked with every one of the data centers and continues to rely on their support to ensure the collection of timely and valid data. These resources are critical in our work, and we have neither the staff or the time to pursue finding TA providers on our own. As NASDSE noted in their comments, “Changing the funding structure does more than change how funds are distributed. It waters down the expertise available to states. The TA centers serve a vital function by providing their expertise to states and assisting them in obtaining the highest quality data possible. Without their assistance, the ability to implement research-based and data informed changes to our K-12 system would be challenging.”

  38. As State Director at the New York State Education Department (NYSED) responsible for implementation and oversight of Part B of the Individuals with Disabilities Education Act (IDEA), I am appreciative of the opportunity to comment on the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) question on how to best provide technical assistance (TA) to states, and the most effective and efficient method of funding this effort. NYSED supports the continuation of funding national technical assistance centers through Option 1. The assistance provided to New York State by the national TA Centers is invaluable as we work to improve outcomes for students with disabilities. We have worked in collaboration with multiple funded networks, including the Center for IDEA Fiscal Reporting (CIFR), the IDEA Data Center (IDC), the National Center for Educational Outcomes (NCEO), and the National Center for Systemic Improvement (NCSI) to strengthen fiscal practices and procedures; to more effectively use data to inform decisions; to engage stakeholders in the revision to our State Systemic Improvement Plan to narrow the scope of the State Identified Measurable Result (SiMR) to focus more deeply on systemic change; and to strengthen capacity building within our State. Options 2-5 will likely result in inconsistent messaging of OSERS requirements and decreased opportunities for cross state collaboration.

  39. As an Education Associate at the Delaware Department of Education, I totally support the continuation of the Technical Assistance centers. The technical assistance that IDC has provided throughout the development and implementation of our SSIP has been invaluable. They have supported us with ongoing data analysis, stakeholder engagement, problem solving, and communication. In addition, the data protocols developed by IDC have improved our data reporting across the Department. The knowledge, experience, and expertise of our TA providers is amazing. We are very grateful for their assistance and look forward to continued collaboration in the future.

  40. As the data manager for B7 in Colorado, I can say confidently that our state’s model for outcomes reporting would not be possible without the national TA centers, particularly DaSy. We simply do not have the resources in-house to accomplish much of the technical work yet the TA centers have helped us realize tremendous efficiency in reporting and transparency. The TA centers have also helped us make huge strides in Part B and Part C data linkages.

    We have utilized TA resources since the beginning of our GSEG grant. Currently, our team uses the TA centers on a regular, monthly basis. We support continued funding for these organizations.

  41. The Council of Administrators of Special Education (CASE) appreciates the opportunity to comment regarding Technical Assistance Funding for IDEA Data Collection across the country. The Council of Administrators of Special Education (CASE) is an international professional educational organization affiliated with the Council for Exceptional Children (CEC) whose members are dedicated to the enhancement of the worth, dignity, potential, and uniqueness of each individual in society. CASE represents special education administrators in local school districts, the individuals charged with responsibility for implementation and financial oversight of special education programs for children and youth with disabilities in schools across the country.

    What challenges does your State face in collecting, analyzing, reporting, and using IDEA Part B and Part C data required under IDEA Sections 616 and 618? Of primary concern to CASE is the amount of training and support necessary to ensure quality data collection given the amount of turn over in state level positions. Direction and support from the federal level is necessary to ensure quality data collection is happening across all of the states.
    To what extent do current Department-funded investments under the TA on State Data Collection program help your State address those challenges? The funding supports the necessary training to gain access to quality data at the state level as well as the national level. There is a good deal of complexity in the data collection process and the TA supports the quality of the process. Commonality across systems and states is desirable.
    Are there other investments that the Department should pursue to meet States’ IDEA data TA needs, and how should these investments be funded? CASE supports the necessary investment to train and provide ongoing technical assistance to each and every state department responsible for collecting IDEA data. We support either a regional or national approach to this technical assistances but we do not support a decrease in TA for states in regard to date collection. We support increased training for LEAs in data collection as well as the SEA. Technical assistance is necessary at all levels in order to ensure quality data collection.
    What do you believe would be the potential benefits or limitations of the following TA funding options:
    a) The Department continues to reserve funds under IDEA section 616(i) (Part B) to fund national TA centers to support the IDEA Part B and C State Data Collection Program: CASE believes this option to be the best option and that we should continue to support the funding of IDEA data collection technical assistances at the federal level.
    b) States apply directly for funding under the TA on IDEA Part B and C State Data Collection program, which they can use to purchase TA on IDEA data collection required under IDEA Parts B and C: CASE does not support a competitive approach to accessing funding for technical assistance for data collection. All states should have robust access to TA in this area.
    c) The Department does not reserve funds under IDEA section 616(i) (Part B) to fund new awards under the TA on State Data Collection Program under IDEA Part B and C and instead provides additional direct, formula funding to States under Part B of the IDEA? This option could also include allowing States to reserve additional State set-aside funding for IDEA Part B State-level activities, which would be used to improve the collection, analysis, reporting, and use of data under IDEA Part B (not Part C). CASE does not support this option and feels strongly that the states should not be left to their own to manage technical assistance for themselves. Instead CASE supports a strong technical assistance approach for data collection that is designed to provide equitable level of support to all Departments of Education and IDEA Data Managers across the country.

  42. Missouri Part B and Part C supports Option 1 to continue to fund national TA Centers to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    OSEP-funded TA Centers currently provide direct support, tools and resources to states, and serve as hubs of technical expertise. Over the last 20 years, federal special education data reporting requirements have continually changed and expanded. This continuous change makes it imperative to have consistent technical assistance that is available to states without going through a procurement process and without states having to worry about inconsistencies between various technical assistance providers.

    To address the directed questions, we experience ongoing challenges in interpreting and implementing changes in federal requirements. Technical assistance is needed across the entire spectrum of the data cycle: collection, reporting, analysis, improvement, and evaluation.

    Products or services that Missouri has used and found beneficial include, but are not limited to:
    • National face-to-face meetings for state staff facilitated by various TA Centers
    • CIFR’s technical assistance with allocations process
    • CIFR’s technical assistance on MOE/CEIS
    • CIFR’s regional conference calls
    • IDC’s various resources on process documentation
    • IDC’s resources for new Data Managers

    Suggestions for improvement of the current TA Center system include the following:
    • Currently, there is overlap in content and staff between the various TA Centers. There are multiple tools that address basic data processes including data governance, system frameworks, documentation protocols, data visualization, etc. The overlap could be greatly reduced by combining some of the TA Centers, so that a smaller number of TA Centers have a broader, clearer focus. This could also help reduce the number of TA Center points of contacts that states have, as well as reduce a perceived feeling of competition between TA Centers.
    • The TA Center(s) should expand the facilitation of state meetings (Data, Fiscal, etc.) where states are able to connect with one another as content experts along with TA Center staff. Data Managers consistently report that the peer-to-peer learning and networking opportunities at these meetings provide the most direct benefit to their work.
    • TA Center(s) should provide more intensive, direct support to new Data Managers. There is a relatively high attrition rate for special education Data Managers. Each year, a new cohort needs the fundamental knowledge and skills to carry out this complex work with fidelity. The TA Center(s) should partner with current state Data Managers and/or by having TA center staff who have recent state experience to ensure the support is relevant in the current landscape.
    • The TA Center(s) need to go beyond the basic requirements of collecting/reporting data and making allocations. Technical assistance needs to address the use of data in improving outcomes for students.

  43. We have found the national TA centers extremely beneficial and have utilized their support in numerous ways. Some of the products we have most often used (templates and guides from the IDC, the Generate product from CIID, and frameworks for data systems and governance from DASY) are high-quality and consistent and I’m not sure this type of TA would be possible with individually state-procured projects or assistance. Additionally, we have worked with multiple TA providers who have given us state specific support for challenges we are facing. Locating TA providers through individual contacts, without the support of a TA Center, would be challenging and could lead to states paying for lower quality assistance. I am in support of continuing to fund the national centers to assist states with capacity building activities surrounding data and evidence based practices.

  44. The Massachusetts Department of Elementary and Secondary Education strongly endorses the U.S. Department of Education’s continuing to fund technical assistance centers for supporting states on the collection and reporting of data required under IDEA Part B, Sections 616 and 618. The services provided by the funded TA centers are invaluable to states in supporting us in meeting federal obligations under IDEA.

    To understand the impact of the proposals to shift funding structures, it is important to understand the extent to which Massachusetts engages with the TA centers and the important role they play in supporting our work. By way of example, we will describe the significant engagement Massachusetts has had with one center one one issue over a four month period – this is only a snapshot of the important work that TA centers have done collaboratively with Massachusetts.

    Massachusetts has worked extensively with the IDEA Data Center (IDC) in the last several months on developing state and local systems responsive to the new regulations governing significant disproportionality in special education. IDC has provided direct, responsive technical assistance to Massachusetts, responding to specific questions as they arise; created tools and resources like the Success Gaps Toolkit and disproportionality measurement applications that have been used by SEA staff, and shared with districts and stakeholders; and facilitated presentations to and networking among states to share best practices and challenges. Staff have attended the IDC Data Conference, participated in monthly or more frequent TA conference calls, and consulted directly with our IDC liaison about specific issues pertaining to calculation methodologies and root cause analysis. These opportunities for support have been invaluable, not only for the resources provided, but for the networking and connections. We have used resources to create State forms and templates for implementation, and communicated with other state identified by IDC as having practices and approaches to this work that are informative for Massachusetts. These are only some of the ways that Massachusetts has worked with IDC this spring. We have similarly relied on other TA centers for support, coordination, and expertise in a variety of areas.

    Massachusetts is concerned that eliminating directly funding the centers through funds reserved by OSERS under IDEA section 616(i) of Part B, and shifting to states themselves the responsibility for procuring technical assistance support, will place a significant burden on states and undermine the collaborative. The impact will be on both time and resources if states are required to contract directly for services. This will create another significant work stream for each state that will not be mitigated by providing funds to states to contract directly with TA providers. Each state will be required to vet TA providers, and engage in complex procurement processes in order to work with them. Under the current system, the federal government has provided this important service for states. The current systems eliminates duplicative and costly activities, and benefits all states. Additionally, shifting this burden to states will result in increased competition for increasingly limited TA resources, and may result in states not being able to use these resources to support their work to improve student outcomes.

    We also have significant concerns that shifting the burden to the states will significantly change the type of work that TA providers can do for states. Massachusetts has become increasingly reliant on support from these centers to help us evaluate IDEA requirements and develop state and local systems to meet them. Eliminating national TA centers would result in less common understanding and coordination of responses to requirements. States will no longer be able to benefit from a national perspective on best practice, nor national coordination of cross-state networks.

    Massachusetts strongly urges the U.S. Department of Education to continue to reserve funds under IDEA to fund national TA centers to support the IDEA Part B and C State Data Collection Program for the benefit of our states, other states, and students with disabilities.

  45. As the Transition Coordinator for the Idaho Division of Vocational Rehabilitation, I support the continuation of the Technical Assistance Centers as described in Option #1 and completely agree with my educational colleagues. The TA provided allows not only for cross state learning, but also cross agency learning. I am thankful for the opportunity to respond to the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) question on how to best provide technical assistance (TA) to states.

  46. Wisconsin Department of Public Instruction supports the continuation of funding national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    I serve as the director of the special education team responsible for the state’s implementation of IDEA. We have found the TA Centers incredibly valuable in carrying out our state’s responsibilities, including the accurate and timely submission of the annual performance report, Child Count, etc. Most importantly, the TA Centers have provided the necessary assistance in our state’s efforts to improve literacy outcomes for students with IEPs. The TA Centers are responsive is their assistance and have established collaborative connections among states engaging in similar efforts.
    Wisconsin supports Option 1 to ensure the TA Centers are funded and states have continued access to the assistance necessary to meet the requirements of IDEA.

  47. I write on behalf of the National Association of State Directors of Special Education (NASDSE), the national nonprofit organization that represents the state directors of special education, the Part B data managers and the 619 early childhood coordinators in the states, the District of Columbia, the U.S. Department of Defense Education Agency, the Bureau of Indian Education, the U.S. territories and Freely Associated States.

    NASDSE thanks you for the opportunity to comment on the U.S. Department of Education’s Office for Special Education and Rehabilitative Services’ (OSERS) question on how to best provide technical assistance (TA) to states, and the most effective and efficient method of funding this effort.

    NASDSE believes the Department should continue with Option 1, funding national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of states to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

    Our members are the state personnel who are charged with implementation of IDEA, which includes the reporting of data for Child Count and the annual performance reports The data collected must be valid and reliable and reported in such a manner as to be used in making important policy implementation decisions to ensure that all students with disabilities are receiving FAPE. The TA centers that are funded under Section 616 of the IDEA have provided tremendous assistance in helping states reach these goals.

    Changing the funding or structure of TA is counterproductive to achieving these goals, as it assumes the states have the resources and time to address data issues as they arise—timely support is key to the ability to provide quality data. The TA centers have the knowledge and information to facilitate states learning from one another. If instead, OSEP chooses to give these funds directly to the states, there will be no opportunity for cross-state learning nor will the states be in a position to more clearly see how they can improve the quality of their data and reporting. Additionally, if changed, the funding structure would not provide an equitable distribution of dollars to every state. Under the proposed approach, smaller states would receive fewer funds, yet their reporting requirements and obstacles to reporting are the same as larger states. Furthermore, pushing funding down to the LEA level would result in even more inequality, with larger school districts receiving more funding, leaving little for smaller districts. An inability to access technical assistance in a timely manner could jeopardize the ability of the states to fulfill the requirements of the law.

    In surveying our members, all the states indicated that they fully support the valuable services provided by the TA centers and do not want to see changes in this regard.

    While we recognize the effort to provide the states with flexibility that will allow them to best meet their individual needs, this is one area in which federal funding and expertise is desired.

    Changing the funding structure does more than change how funds are distributed. It waters down the expertise available to states. The TA centers serve a vital function by providing their expertise to states and assisting them in obtaining the highest quality data possible. Without their assistance, the ability to implement research-based and data informed changes to our K-12 system would be challenging.

    Not only do the current TA centers provide invaluable support, the state directors have clearly expressed concern over the dissolution of the regional resource centers that also provided extensive support to states. And while it is not always clear which center states should contact about a specific issue, this concern can easily be remedied and the TA centers have the knowledge to inform a state as to where their inquiry should be directed.

    We implore the Department to carefully consider the states’ input on this proposal as the state directors are the direct recipients of this support. As the intended recipients of the use of these funds, the state directors emphatically reject any proposals to revamp how these funds are distributed so that they can continue to provide the best possible strategies to ensure positive outcomes for all students, including students with disabilities.

    • Good morning. Thank you to the Department for the opportunity to provide comments. As the state director of Kansas, my preference is option 1, funding national technical assistance centers to improve capacity of states to meet requirements as states, and to provide the department the data you need to report outcomes for students with disabilities to Congress. As a state director for the past 12 years, the most frustrating part of my responsibilities is getting support from within our agency for the data collection, analysis and reporting of IDEA requirements. Without the expertise of staff from IDC, CIID and CIFR, Kansas would not be in the position we are currently in verifying 618 data as well as the fiscal requirements of State Maintenance of Financial Support, Maintenance of Effort etc. As a state agency, we do not, nor will be have the expertise that is needed for the complexities of data the department is expected to report to Congress. If there are concerns about the type of support provided to states, I highly recommend that the department ask state directors and data managers for how to improve services. Everything that we do in education can be improved upon. It is my opinion that if the department chooses any option other than 1, the department is compromising their own ability to accurately report to Congress as required.

  48. As the State Director for Colorado, I would echo the comments of my colleagues and would support Option 1. The assistance and support through the national TA centers have been very helpful in capacity building at the SEA level. It is very unlikely that we would be able to duplicate these supports through the other options proposed above. Colorado would advocate that funding for the national TA centers be continued.

  49. As a member of both my local school board and special education cooperative, Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618 – is the most appealing.

    This is primarily because the current system has already adapted to the needs of small communities like mine, via state agencies and regional TA Centers. Resetting those relationships by changing funding streams, processes, and/or formulas would most certainly result in lost ground, especially in smaller communities with extremely unique needs.

    As we have experienced in Kansas over the last decade, changes in funding formulas and procedures have resulted in wide swings in funding, making long term planning difficult due to uncertainty and knee-capped efforts at improving educational program for all students – especially our most at risk students. While the current system isn’t perfect – it’s understood and effective in addressing our regional, state, and local needs.

  50. Speaking as a state agency recipient of current Department-funded investments under Section 616(i) (Part B) of IDEA, we support the option (Option 1) to continue funding national TA Centers to help build and improve capacity to meet Part B and C data collection requirements under Sections 616 and 618. These investments that are passed through the TA centers have allowed our state to access high quality expertise and to connect with other states in collaborative engagements that would not be possible in the absence of these centers. Options 2-5 would impact states ability to freely access this type of support and would significantly decrease the opportunities for state to state collaboration. We have been fortunate in having instant access to TA personnel in a number of support areas that has allowed our State to better collect, analyze, and report data specifically in our work toward significant disproportionality, the SSIP and SPP/APR.

  51. I am an assistant director at the Kansas State Department of Education (KSDE). KSDE is responsible for implementation and oversight of Part B. The challenges our State faces in collecting, analyzing, reporting, and using IDEA Part B data is having the necessary capacity and expertise to effectively analyze the data we collect. Analyzing data in a way that enables us to use it to inform our support to school district is best done by experts who do that type of work all of the time. The Department-funded investment in the TA for State Data Collection program allows us to be able to tap into national experts whose careers are dedicated to best practices in data collection, analysis, and reporting. As a State we have worked closely with many of these data centers to improve our practices in data collection, analysis, and reporting and seen fantastic results from our work with them. Support from these data centers have improved our data practices in ways we likely could not have done our own. The data centers provide us access to national experts and even with additional funding it is unlikely we could replicate the level of support we receive from the data centers. There are not other investments that the Department should pursue to meet States’ IDEA data TA needs, other than reserving the full amount under this set aside.

    In my opinion, these are the potential benefits or limitations of the following TA funding options:

    a) The Department continues to reserve funds under IDEA section 616(i) (Part B) to fund national TA centers to support the IDEA Part B and C State Data Collection Program

    This is the best option for the reasons I have stated above.

    b) States apply directly for funding under the TA on IDEA Part B and C State Data Collection program, which they can use to purchase TA on IDEA data collection required under IDEA Parts B and C;

    The limitations of this method is that states, especially very small states, could not replicate the level of support received from the TA centers. Also, the current method is working very well and there is no reason to change to a method that will likely not work as well.

    and

    c) The Department does not reserve funds under IDEA section 616(i) (Part B) to fund new awards under the TA on State Data Collection Program under IDEA Part B and C and instead provides additional direct, formula funding to States under Part B of the IDEA? This option could also include allowing States to reserve additional State set-aside funding for IDEA Part B State-level activities, which would be used to improve the collection, analysis, reporting, and use of data under IDEA Part B (not Part C).

    The limitations of this method is that states, especially very small states, could not replicate the level of support received from the TA centers. Also, the current method is working very well and there is no reason to change to a method that will likely not work as well.

    Please reserve the maximum amount of funds under this set aside and continue to fund the TA centers to support states in effective data collection, analysis, and reporting. Our state has received excellent support from these TA centers and looks forward to continuing to work with them to improve data practices in our state.

  52. In many states Students diagnosed with Dyslexia and Other Specific Learning Disabilities are denied services. The difficult part is that the denial of services are not required to be tracked. If the data was collected and there was mandatory reporting of denials then the LEAs would see just how many students who need services are not getting them. The tracking of the data would allow schools, school districts, and Depts of Education to analyze the criteria for a denial of services for this subset of students.

  53. As an Education Associate in the Delaware Department of Education, I support the continuation of the Technical Assistance Centers as described in Option #1. The technical assistance and expertise provided by the Centers have been invaluable to us as we have negotiated our way through the new Significant Disproportionality regulations, the SSIP and SPP/APR, fiscal reporting and overall capacity building within our state. The tools developed and made available to SEAs from IDC and CIFR have assisted in improving the quality of data collected and reported. The Multi-State Collaboratives and Peer-to-Peer Exchanges are incredibly helpful with problem solving and have fostered knowledge of other larger state systems that we’ve found useful. The staff we work with across multiple centers are very knowledgeable, available, and it would be a loss not to have them available as a resource.

  54. New Jersey supports the continuation of the Technical Assistance Centers as described in option #1 above. The State has utilized the expertise and technical assistance provided by the centers in a variety of ways including data mapping, significant disproportionality, the SSIP and SPP/APR. CIFR has been an invaluable resource providing ongoing support to ensure the State meets all obligations set forth in the IDEA. New Jersey participates in two Cross State Learning Collaboratives and has incorporated this work across the office. The staff are all extremely helpful and knowledgeable and we would be at a loss without their work.

  55. North Carolina EC Division actively engages support from multiple OSEP TA centers to assist with federal reporting, funding and data needs. North Carolina has been a part of the DaSy Part C to B linking Cohort for several years and has recently completed the Charter and MOU to be able to link data from the two agencies. We have also been a part of the Part B Data manager coaching group and steering committee and used the many reporting resources made available by the IDC center. Just recently we had a new section chief attend the CIFR conference and he was able to ask questions and become familiar with the expectations of his new role. North Carolina greatly appreciates the work of the OSEP TA centers and we certainly hope that they will continue to be available to us.

    Thank you,

    Kelley Blas – Part B Data Manager
    Special Programs and Data
    Exceptional Children Division
    Phone: 919-807-3967

    Karl Pond, Enterprise Data Manager
    North Carolina Department of Public Instruction
    [P] 919-807-3241

  56. The Wisconsin Department of Public Instruction supports “continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.”

    The Department of Education’s investment supporting the national TA Centers has been incredibly worthwhile. I am a federal fiscal monitoring consultant on the Special Education team at the Wisconsin Department of Public Instruction. Since the Center for IDEA Fiscal Reporting (CIFR) was established, I have felt that the work around IDEA fiscal compliance is finally getting the national guidance State Education Agencies (SEAs) have needed since I entered into this field 13 years ago.

    Regardless of how well-established or seasoned some states are regarding IDEA fiscal compliance and monitoring, most of our standards and procedures were built on our own interpretation of the IDEA regulations. We assumed we were doing it correctly, in our state silos, until one of us would receive an audit or monitoring finding. Now, through CIFR, we actually have a set of technical assistance built specifically for SEAs implementing fiscal monitoring systems and LEA monitoring tools. Not only is the technical assistance written in plain language, the CIFR staff creating the guidance have a true understanding of how complicated and different each state’s public education funding system is – along with the difficulties of not having state investments into web-based systems or fiscal staff capacity. Having this knowledge, CIFR is truly responsive to the needs of the SEA staff who seek their guidance.

    For Wisconsin, CIFR has been essential as a resource. When the proposed rules around IDEA Maintenance of Effort (MOE) were released, a cohort of states worked with CIFR to understand how the regulations were to be implemented. Prior to CIFR, we would have done the best we could and hoped we were doing it correctly. With CIFR, we were able to discuss the changes as state colleagues and request that CIFR take our questions and clarifications to OSEP. This was very important because the changes meant a major overhaul of Wisconsin’s web-based MOE monitoring system. It is not an investment Wisconsin could take lightly – we needed to know that how we planned to change our system was going to be in compliance with the new regulations. Because CIFR was able to approach OSEP with our questions as one group, the turnaround response time was very quick. And because the states involved all agreed on the questions before they were sent, when OSEP did provide additional guidance, we truly felt we were all on the same page in our understanding of the proposed rules.

    As with every state, Wisconsin’s work around fiscal monitoring is built piece-by-piece, year-by-year. As new technology emerges, as new tools are created, we are provided opportunities to become more efficient and accurate. Wisconsin is very pleased that CIFR has been able to add IDEA Part B allocations to their focus. Our next large scale project is moving our IDEA Part B allocation calculations to a web-based format. Again, as this is a significant investment in our web-based development, we want to make sure we are doing everything correctly. One of the reasons we are moving our process is because of the creation of additional independent charter schools within our state. Prior to the coming year, the number of independent charter schools was relatively small and their location was all within the same jurisdiction – thus our allocation process was not overly complicated. However, with our state expansion of independent charter schools, understanding the creation and adjustment of base amounts has now risen to the top of what we as a state need to understand. The impressive materials put out so far by CIFR have made us feel very confident that we will be able to implement allocation creations correctly. Not only that, but as we build and develop our written procedures regarding allocations, we know we can rely on CIFR staff for continuous feedback on our efforts.

    In conclusion, I will state the following: the Wisconsin Department of Public Instruction invests and supports the SEA’s fiscal monitoring of IDEA. We in the fiscal monitoring field see CIFR as one of the best investments made by OSEP to support our work. I have to assume that states that are just beginning their support of fiscal monitoring systems must see CIFR as essential to any type of progress. The knowledge, dedication, and integrity of the CIFR staff make them very approachable by any SEA, regardless of where they are in relation to implementation and development of their own fiscal monitoring systems.

  57. Our State faces challenges in collecting, analyzing, reporting, and using IDEA Part B and Part C data required under IDEA Sections 616 and 618. We receive part of our data from another state agency, making it a cumbersome and difficult process. We also do not have Part C oversight. We use the National TA Centers regularly. The TA Centers are instrumental in providing high-quality assistance. They are timely and accurate in their responses when requested. We strongly support Option 1. From the data side, at all levels, we can use some assistance in communicating with the program side (with districts as well); training to pull both sides together. The access to the TA centers working and meeting our needs and we also have the support we need to be more effective as a SEA. If the TA centers were eliminated or restructured, this would be a limitation and create a burden on the state in the way of time and efficiency.

  58. Connecticut Part C has always been an active participant in any TA offered by NECTAC, NECTAS, NCSEAM, ECTA, ECO, DaSy, WESTAT, IDC, NERRC and NCSI (did I forget any?) They are critical to helping isolated state leads connect with their job-alike peers in other states. Through these cross-state relationships we all grow and develop knowledge about how to improve our state systems. Connecticut families and providers are better off as a result of the TA we have received from these centers and our peers.

    As a 22-year Part C Data Manager who just became the Part C Coordinator, I cannot imagine trying to train a new Data Manager this Spring on my own. I am counting on the data TA centers to help with this transition.

    In addition to data, we are hoping that the re-authorization of IDEA will permit OSEP to fund a Fiscal TA Center like CIFR for Part C. We need help maximizing the many revenue streams that are required to support Early Intervention.

  59. I wholeheartedly agree with my colleagues, continuation of the funding for these TAs centers has been crucial to our being able to remotely keep our heads above water given all of the other demands at the SEA. They are a lifeline and key in supporting high quality information and supports of all types. Most recently, our state utilized the online Child Outcomes Summary training modules from ECTA to train our entire state. There is no way that could have been done internally, and this also provides the same information to all of the states so that we are all understanding this in a standardized way. We also use the ECPC, DaSy, and IDC just to name a few more. Please consider Option 1:Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

  60. All states face significant challenges in collecting, analyzing, reporting, and using IDEA Part B and Part C data required under IDEA Sections 616 and 618. The current Department-funded investments under the State Data Collection program are immensely valuable to SEAs. Speaking as the Part B State Director in Oklahoma, these investments passed through TA centers have been instrumental in improving the capacity of our State to meet data collection and reporting requirements. We support option 1 listed above. There is no possible way that states could replace the great work being done by these TA centers through options 2-5. Even noting the valuable work that Neal Kingston’s team completed with the support of the GSEG grants (DLM), I sincerely hope that the Department continues to fund the TA centers. I’m not opposed to increasing funding in order to reinstate the GSEG program. However, using the funds solely for options 2-5 would create instability and increase demands on states to individually obtain high quality technical assistance at the level we are now receiving. The current TA centers provide deep expertise and help to facilitate increased collaboration between states that would be immensely difficult to replicate. IDC, CIFR, and CIID, in particular, have been a great support for our State and we are very thankful for everything they do to help us meet the IDEA’s data collection and reporting requirements.

  61. As Montana’s Part C Coordinator, I am the single staff member responsible for all facets of coordinating the Part C program in Montana. DaSy team members and IDC team members are instrumental assistants in many of MT’s recent successes: data management system and COS rating systems, and on and on. Please consider Option 1: Continuing to fund national TA Centers from the funds reserved under Section 616(i) (Part B) of IDEA to improve the capacity of States to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.

  62. As a former Associate Commissioner of Education for the state of Kentucky, but also as a public university faculty member who as worked on GSEG grants that have greatly improved the quality of data collected on hundreds of thousands of students in about 20 states and simultaneously led to improved outcomes for students. Based on these experiences I would very much hope that the GSEG program be reinstated under the second option above, “Inviting SEAs and LAs to directly apply for funds reserved under Section 616(i) (Part B) to purchase TA to improve their capacity to meet their IDEA Part B and Part C data collection requirements under Sections 616 and 618.”

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