RE: Agency Information Collection Activities; Comment Request—State and Local Educational Agency Recordkeeping and Reporting Under IDEA Part B [Docket No.: ED-2025-SCC-0976]
Submitted via online: https://www.regulations.gov/search?filter=ED-2025-SCC-0976
Dear Mr. Santy:
On behalf of the Autism Alliance of Michigan (AAoM), we appreciate the opportunity to submit comments on the Office of Special Education and Rehabilitative Services’ (OSERS) notice proposing to extend existing State and local educational agency (LEA) information collection requirements under Part B of the Individuals with Disabilities Education Act (IDEA).
AAoM is a statewide nonprofit organization dedicated to improving educational access, quality, and outcomes for individuals with autism and other disabilities across Michigan. Through policy advocacy, data analysis, and collaboration with families, educators, and state leaders, we work to advance equitable implementation of IDEA and ensure that students with disabilities receive the services and protections to which they are entitled under federal law.
AAoM supports OSERS’ proposal to continue these long-standing data collection and reporting requirements. The areas identified in the notice—private schools and parentally placed private school students, State high cost funds, notification of free and low-cost legal services, early intervening services, hearing officers and mediators, State complaint procedures, and LEA applications under IDEA Part B—are foundational to accountability, transparency, and effective oversight of special education systems.
Importance of Maintaining Existing IDEA Part B Collections
The data collections OSERS proposes to extend have been in place for nearly two decades and serve critical purposes that extend beyond federal reporting. These requirements ensure that States and LEAs maintain essential information needed to safeguard students’ rights, inform families, and support sound fiscal and programmatic decision-making.
In particular:
- State High Cost Fund data are essential to understanding how States mitigate the financial impact of serving students with the most intensive needs. Transparent and consistent collection of this information supports equitable funding systems and helps prevent inappropriate cost-driven placement decisions that can undermine IDEA’s least restrictive environment requirements.
- State complaint procedures and notification of free and low-cost legal services are core procedural safeguards under IDEA. Continued data collection in these areas supports family awareness, access to due process, and timely resolution of disputes—especially for families who face barriers navigating complex special education systems.
- Parentally placed private school student data remain critical to ensuring States meet their child’s obligations and appropriately calculate and allocate proportionate share funds, a long-standing area of confusion and inconsistency for families and districts alike.
- Early intervening services and LEA application information help States and the Department monitor how federal funds are used to support early support and compliance with IDEA assurances, including maintenance of effort and fiscal accountability.
Burden Considerations and Data Utility
We agree with OSERS that continuing these collections does not impose an undue burden on States or LEAs. These requirements are well-established, integrated into existing administrative processes, and, in many cases, only require reporting when changes occur or when information is shared with other public agencies or the public.
Importantly, the value of these data far outweighs any minimal administrative burden. Eliminating or weakening these collections would reduce the quality, utility, and clarity of information available to the Department, States, families, and advocates—without producing meaningful efficiency gains.
Implications for Michigan Families and Ongoing Reform Efforts
In Michigan, AAoM works closely with families, policymakers, and education leaders on issues related to special education finance, accountability, and procedural safeguards. Continued access to consistent State- and LEA-level information is essential to these efforts.
Maintaining these IDEA Part B data collections supports:
- Monitoring equitable access to services,
- Identifying systemic challenges before they escalate into widespread noncompliance,
- Informing policy reforms grounded in real-world data, and
- Ensuring families have the information they need to advocate effectively for their children.
Recommendations
AAoM respectfully urges OSERS to:
- Approve the extension of all existing IDEA Part B information collection requirements outlined in the notice without reduction in scope;
- Affirm the importance of these collections for transparency, civil rights protections, and fiscal accountability under IDEA; and
- Continue engaging State and stakeholder partners to identify opportunities to streamline data systems while preserving essential information and safeguards.
Conclusion
Data transparency and accountability are cornerstones of IDEA’s promise to students with disabilities and their families. The information collection requirements addressed in this notice play a vital role in ensuring that promise is upheld. AAoM therefore supports OSERS’ proposal to extend these requirements and appreciates the Department’s continued commitment to responsible oversight and equitable implementation of IDEA Part B.
Thank you for considering these comments and for your continued commitment to the rights of students with disabilities and their families.
Please contact AAoM CEO & President, Colleen Allen, colleen.allen@aaomi.org or Director of Statewide Education, Heather Eckner, heather.eckner@aaomi.org with any questions.
Sincerely,
Heather Eckner, M.A.Ed.
Director of Statewide Education
Autism Alliance of Michigan
About the Autism Alliance of Michigan
The Autism Alliance of Michigan (AAoM) is a 501(c)(3) organization serving as a trusted ally and partner for thousands of families across the state. AAoM’s mission is to lead efforts to raise expectations and expand opportunities for people connected to autism across their lifespan. The organization’s Education pillar drives initiatives that address systemic barriers to education, focuses on student-centered advocacy, and educates families on related topics – working towards its goal to make Michigan a top 10 state for special education outcomes. For help finding resources, providers, and information contact our MiNavigators at 877-463-2266 (AAOM) or email at navigator@aaomi.org. More information about AAoM’s Education pillar can be found at: https://autismallianceofmichigan.org/education-initiatives/.