AASA Responds to OCR Mandatory Civil Rights Data Collection

Today, AASA posted our response to Office of Civil Rights (OCR) Civil Rights Data Collection for 2021-2022 school year. This data collection will hit districts in January 2023. Currently, districts are reporting data for the 2020-2021 Civil Rights Data Collection. This is the first time OCR has required back-to-back collections. Here is an excerpt of our comments:

"If there was ever a moment in time for the U.S. Department of Education to recognize the hardship of increased data collection it would be now. Instead, by ignoring or simply dismissing the reality of district personnel and their workloads during the third year of a global pandemic, the 2021-2022 collection proposes to increase the CRDC collection by 47.5 percent when compared to the 2020-2021 collection. Moreover, the Department of Education sets a record over the past decade in the number of hours required to comply with the collection. Even if these estimates, while low, are accurate, the burden a decade ago on districts was estimated to be 8.1 hours per elementary school and 14.9 hours per secondary school.  For the 2021-2022 collection the burden for elementary schools is estimated to be 13.7 hours per school survey and for secondary schools, the burden is estimated to be 22.6 hours per school survey.

Each year we see enormous shifts in the data that is revised and collected. This year the whiplash in data elements is particularly clear as we have an unprecedented CRDC collection happening in back-to-back years. It is our view that either OCR is required to collect this information because to do so would be to leave it clueless as to whether a student’s civil rights are being infringed upon on a permanent basis (as the student’s civil rights are not immutable) or OCR is collecting considerable amounts of 'nice-to-know' rather than 'need-to-know' data with little regard for the burden these reporting requirements place on LEAs and school personnel. If it is the latter, which AASA suspects, then it is highly questionable to place this burden on district personnel during a pandemic when it comes at the direct cost of removing key instructional staff to perform data collection duties."

You can read our full comments here.