December 2024

On December 16, AERA submitted comments on proposed updates to the 2025–26 and 2027–28 Civil Rights Data Collection (CRDC). The CRDC is a mandatory data collection administered by the Department of Education Office for Civil Rights (OCR) and includes data from schools and school districts on student enrollment; access to courses, programs, and school staff; and school climate factors, such as bullying, harassment, and student discipline.

The OCR proposed maintaining many of the fields that were included in the 2023–24 CRDC, with a couple of changes to account for updating data fields on remote, hybrid, and in-person instruction in general and removing similar questions focused on those settings due to the COVID-19 pandemic. OCR is also proposing to collect data related to students who are served in non–school district settings but are enrolled in the school districts.

In addition, OCR sought input into five data topic areas being considered in updates for 2025–26 and 2027–28: informal removals of students from classrooms; defining and seeking input on questions on threat assessments; incorporation of the updated Statistical Policy Directive (SPD) 15 on race and ethnicity standards; disaggregation of referral and arrest data by race and ethnicity for students with disabilities who are served under Section 504 of the Rehabilitation Act of 1973; and teacher certification in specialized areas.

In the comments, AERA Executive Director Felice J. Levine noted appreciation for the maintenance of many of the data fields in future iterations of the CRDC, while also urging that the data be collected on an annual basis. The comments also addressed three of the five topic areas where OCR had requested input.

The comments encouraged OCR to collect data on threat assessment teams with the current discontinuation of the School Survey on Crime and Safety, while also maintaining the definitions and questions used by the National Center for Education Statistics (NCES) in that survey for comparability. The comments also urged OCR to collect arrest and referral data for Section 504 students, as it would be useful for researchers to analyze disaggregated data by race and ethnicity that would be inclusive of both classifications of students with disabilities under Section 504 and IDEA.

The comments also emphasized partnership between OCR and NCES in implementing SPD 15 in the CRDC. In response to a directed question on whether OCR should request an exemption from the detailed reporting categories under SPD 15, Levine wrote:

We urge OCR not to seek an exemption from collecting data with the detailed categories included in the revised SPD 15.

The updated reporting categories in SPD 15 will be important for better understanding and addressing disparities within the minimum race reporting categories, as the detailed reporting categories may illuminate disparities that may otherwise be masked in a larger minimum reporting category for race and ethnicity.

OCR will consider comments received during the 60-day public comment period and will issue updates during a 30-day public comment period.