Today is the last day you can submit a comment on a proposed regulatory change that would damage our ability to track school performance.
The U.S. Department of Education is proposing to continue limiting performance data reported by states to just a single “percent proficient” measure, showing the proportion of students in any given school who cross the state’s chosen proficiency threshold.. This contrasts unfavorably with the approach taken from 2009 to 2019, when states reported the number of students scoring in each of several different categories.
COVID made the effect of the 2019 change obvious. Because detailed education data was unavailable for around 6000 of the 14000 districts in the country and data for most charter schools was unavailable, performance trends and details of which subgroups were most impacted during the pandemic were difficult to track.
The deadline is today. Please consider submitting a public comment to support restoring full reporting of student performance in grades 3-8 for math and reading.
Students have continued to take the assessments that were previously tracked, so a return to more detailed data reporting wouldn’t impact student workload, only legibility. The CEP values the ability to track academic trends, evaluate instructional quality, and identify areas for academic improvement. The more reliable and detailed the data available, the better.
If you’d like to comment, you can do so here. Again, the deadline is today, so please do so immediately if you intend to do so at all.
You can use the quick template below or write your own. A few sentences will help education research and analysis continue and further our mission to promote a culture of excellence in American education.
“I am writing to express my strong opposition to the U.S. Department of Education’s May 2025 proposal to continue limiting performance data reporting in EDFacts.
To maintain high standards in public education, we must have access to detailed, transparent, and comparable student achievement data. A single "percent proficient" figure is insufficient for evaluating academic growth, identifying excellence, or guiding improvement efforts.
I support the original November 2024 proposal that would restore reporting of student counts in each performance category for reading and math. This level of detail is critical for researchers, educators, and policymakers committed to strengthening academic outcomes nationwide.
Please reinstate the requirement for full performance-level reporting beginning in the 2025–26 school year.
Thank you.”
[Your Name – or "Submitted anonymously"]
For those who want a few more details, the Educational Opportunity Project at Stanford has a useful summary of things, which we’ve excerpted below:
Background
The development of the Stanford Education Data Archive relies on the EDFacts data collection, an initiative by the U.S. Department of Education to centralize unsuppressed student performance results in a standard format from each state.
From 2009 to 2019 state education agencies (SEAs) reported detailed data to EDFacts including the number of students scoring in all performance categories in each district and school. After 2019, the EDFacts data collection was changed: since 2021, SEAs report only a single performance measure – the proportion of students above the state’s proficiency threshold.
Because of this change, our team has relied on public state data to develop 2022-2024 SEDA estimates. The SEDA data are much less comprehensive in these years and yield an incomplete picture of student learning and school improvement in America. For example:
Data are available for only 8,000 of the 14,000 districts in the country.
Data for most charter schools are unavailable, unless their data are reported a part of traditional public school districts.
Measures of learning for subgroups of students (such as economically-disadvantaged students) are not available in many of the 8,000 districts.
No data are available for some states, including Maine, Alaska, and New Mexico.
In November 2024, ED proposed changes to the EDFacts data collection that would have SEAs resume reporting more detailed information on the performance levels of students only on federally required math and reading tests in grades 4 and 8. We strongly support this proposal because it would re-enable the detailed SEDA estimates in future years.
However, in May 2025, ED retracted the November proposal and instead proposed to continue the limited data collection procedures that have been in place since 2019. We hope that you will help us oppose this latest proposal and request that ED collect test score data in multiple performance categories in reading and math for students in grade 4 and 8 for the 2025-26, 2026-2027, and 2027-2028 school years.
How to comment
Please click this link if you would like to submit an individual comment.
During the open comment period, any person or group may submit a comment in response to a proposed rule. The hyperlink above will direct you to the comment form.
Please follow the steps below to ensure your comment is submitted.
Enter your comment that expresses (a) your disagreement with the May 2025 proposal to continue the limited EDFacts data collection and (b) your support of the November proposed change for state educational agencies to report multiple performance levels on math and reading assessment results for students for grades 4 and 8 to EDFacts. You can enter your comment in the form or attach your comment as a file. You may also attach other supporting documents to your comment.
You can choose how to identify yourself or you may comment anonymously.
You will have the choice to enter your contact information.
Ensure that you have completed all required fields, then select the “Submit Comment” button.
Reminder: Submitting a comment into an official docket means any personal information included in your comment text and/or uploaded attachment(s) may be publicly viewable on the web. If you are submitting a comment anonymously, please ensure you do not include any personal information in the comment text and/or uploaded attachment(s).
Credit is owed to RHG Burnett for bringing this to our attention.
Why is the DOE still open and staffed?