The following comment was provided on behalf of DEC in reference to the request for comments by The Office of Special Education and Rehabilitative Services (OSERS). The comments request input from the field on the Use of Part B Program Funds for Technical Assistance to States on IDEA Data Collection.
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.
We encourage you, as DEC members, to continue to express your opinion. The comment period ends May 24, 2018.
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