AASA Statement Concerning ARRA Data Reporting Requirements

May 24, 2011
Contact: Kitty Porterfield, kporterfield@aasa.org, 703-774-6953



Under Section 6401 of the America Competes Act (see below), any school district whose state applied for and accepted funds under the recent American Restoration and Reinvestment Act (ARRA) is now required to submit to the state new and comprehensive information—with identifying information—on every student and every teacher in their school district. This regulation applies to all U.S. school districts.

Section 6401 (e)(2)(D), listed below, details the data that are to be reported to the state departments of education. The U.S. Department of Education has provided a form to the states to make school district reports uniform. Collection of this information by the states will be completed by Sept. 30, 2011.


This regulation represents the most comprehensive collection of student and teacher data ever undertaken by the federal government. This is not just schoolwide data, but includes the linking of every student’s grades, state test scores and college readiness test scores to individual teachers. There are a number of serious concerns about these regulations:

  • Privacy rights. The regulation raises huge student privacy concerns because the complete transcript of every single student in public schools will be available in a single file. Any breach of state files will make hundreds of thousands to millions of student records public.
  • Cost. The cost in time and resources to state governments and to individual school systems will be significant. Even today, the ability of schools and school districts to collect data digitally varies greatly across the country. Compliance will first require new technical expertise to develop the software to compile the records in each district and each state, adding to the cost and potentially slowing down the reporting.
  • Reliability and usability of data. Student transcripts and grading policies vary greatly from district to district and state to state. Useful analysis and comparisons will be all but impossible. Additionally, the amount of data will be sufficiently large that analysis may take years to complete, rendering the data useless for classroom improvement.
  • Future use of the data. Staff members of the U.S. Department of Education have said that the records are only for state use. But the possibility remains that the data will be compiled nationally by federal contractors who may not be as concerned about privacy concerns as parents or schools. Since the data will not be statistically reliable, any use for comparison, for justification of policy changes, or for teacher evaluation will be flawed from the outset.

In August 2009, AASA responded to the then proposed regulations with a letter to U.S. Secretary Duncan, which said in part:

AASA strongly applauds the development of a robust longitudinal data system at the state level that interfaces with local data systems. We support the Department's efforts to increase the quality of the state assessment data delivered to the classroom level. The state assessments will become meaningful at the classroom level if/when teachers can receive data that demonstrates what individual students know in an instructionally useful timeframe. Without this level of data driving down to the school and classroom levels, the state assessments are no more than just a missed day of instruction.

We would like to note many school districts cannot participate in the robust data system envisioned by the America Competes Act because they do not have the broadband access at the district or school levels. While the focus is on the state data systems, the success of these systems will be based on the ability of local school districts to transfer their data to the states.

The concerns expressed in that letter remain. Given the severe blows that have been dealt to school districts across the country by the continuing economic crisis, schools have been unable to upgrade their broadband access or focus on data collection. We believe, therefore, that if we are to move forward toward the goals of the America Competes Act, we must take a step back and set realistic interim steps.


The American Association of School Administrators therefore asks the U.S. Department of Education to provide immediate regulatory relief for all schools in this difficult and expensive task.

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AASA Statement Concerning New ARRA Data Reporting Requirements


America Competes Act

Section 6401 (e)(2)(D)

(D) REQUIRED ELEMENTS OF A STATEWIDE P-16 EDUCATION DATA SYSTEM- The State shall ensure that the statewide P-16 education data system includes the following elements:

(i) PRESCHOOL THROUGH GRADE 12 EDUCATION AND POSTSECONDARY EDUCATION- With respect to preschool through grade 12 education and postsecondary education--

(I) a unique statewide student identifier that does not permit a student to be individually identified by users of the system;

(II) student-level enrollment, demographic, and program participation information;

(III) student-level information about the points at which students exit, transfer in, transfer out, drop out, or complete P-16 education programs;(IV) the capacity to communicate with higher education data systems; and

(V) a State data audit system assessing data quality, validity, and reliability.

(ii) PRESCHOOL THROUGH GRADE 12 EDUCATION With respect to preschool through grade 12


(I) yearly test records of individual students with respect to assessments under section 1111(b) of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6311(b));

(II) information on students not tested by grade and subject;

(III) a teacher identifier system with the ability to match teachers to students;

(IV) student-level transcript information, including information on courses completed and grades earned; and

(V) student-level college readiness test scores




About AASA

The American Association of School Administrators, founded in 1865, is the professional organization for more than 13,000 educational leaders in the United States and throughout the world. AASA’s mission is to support and develop effective school system leaders who are dedicated to the highest quality public education for all children. For more information, visit www.aasa.org. Follow AASA on twitter at www.twitter.com/AASAHQ or on Facebook at www.facebook.com/AASApage.