February 10, 2022

Response to the US Department of Education’s Civil Rights Data Collection Request for Information

Comment     

CEO Action for Racial Equity is a Fellowship of over 100 companies that mobilizes a community of business leaders across multiple industries and geographies to advance public policy.  Part of our advocacy focus is Early Childhood Education (ECE), inclusive of childcare and preschool.

Responding to your request for comment on “(1) Is this collection necessary to the proper functions of the Department”, we respectfully urge the Department to review proposed data collection measures through a racial equity lens.

In particular, we support reintroducing DG ID 955 indicating whether the LEA’s preschool program is provided to specific groups of children, including children with disabilities (IDEA), children in Title I schools, and children from low-income families. In addition, DG ID 954 will allow assessment of the children being served in full-day or part-day programs and the cost to parents, which could shed a light on underserved demographics.

We also support the collection of data pertaining to “Corporal punishment instances –preschool” (DG ID 1010), “Discipline of preschool children table” (DG ID 921) and “Suspension instances – preschool” (DG ID 1008), but recommend that for every category set, the data also include the race and ethnicity of the children who are subjected to corporal punishment, discipline, and suspension, respectively. Studies show that Black children – particularly Black boys – receive corporal punishment, are disciplined and suspended at a higher rate than their non-Hispanic white peers, all of which can adversely impact a child’s ability to access a quality education. (U.S. Department of Education, Office for Civil Rights, “School Climate and Safety”, (revised May 2019)). Data collected should be sufficient to measure key performance indicators and outcomes by race and ethnicity on a disaggregated basis. This information is vital for a robust review of programs to investigate the root causes of racial disparities and unintended bias, and work to address them.

Thank you for your consideration.