September 2025

On September 8, AERA submitted comments in response to a 30–day public comment period for the 2025–26 and 2027–28 cycles of the Civil Rights Data Collection (CRDC). The CRDC is a mandatory data collection administered by the U.S. Department of Education’s 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 AERA response focused on four areas:

• Restoration of data indicators for gender identity, including a non-binary category, that had been removed
• A call for the Education Department to ensure that the National Center for Education Statistics (NCES) is able to conduct and disseminate high-quality data on school expenditures from the School-Level Finance Survey (SLFS)
• Recommendation for the Education Department to use detailed reporting categories for future CRDC cycles in alignment with revisions to Statistical Policy Directive 15
• Reiterate the recommendation from the 60–day comment period to disaggregate Referral and Arrest Data for Section 504 Students by Race/Ethnicity

OCR launched the process through an initial 60–day public comment period in 2024 (read AERA’s response here). A 30–day comment period began in January but was withdrawn in February to allow the Department of Education time to align data indicators with the Executive Order, “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.” AERA and 10 education research organizations urged the Department of Education in a July 8 letter to take immediate action to move the CRDC forward.