Recommendation: The Assistant Secretary for the Office for Civil Rights should revise its CRDC business rule to require that every school district reporting zeros, regardless of district size or numbers of students with disabilities, affirm the zeros are correct during the CRDC data submission process. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and school districts that report very low numbers of incidents and set data-driven thresholds to detect such incidents. (Recommendation 2)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and schools districts that report very high number of incidents and set data-driven thresholds to detect such incidents. (Recommendation 3)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should apply the CRDC business rule targeting illogical data at the school level to all schools, regardless of the number of incidents reported. (Recommendation 4)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should identify the factors that cause underreporting and misreporting of restraint and seclusion and take steps to help school districts overcome these issues. (Recommendation 5)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should further refine and clarify federal restraint and seclusion definitions and take steps to ensure that this information is conveyed to school districts. This could include providing common classroom scenarios that highlight the differences between a restraint and an escort, and a time out and a seclusion. (Recommendation 6)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: To enhance participation in and strengthen management of federal student aid programs for teachers, the Secretary of Education should direct Federal Student Aid's Chief Operating Officer to review the underlying cause of the known erroneous conversions to ensure steps Education has taken are sufficient to address the problem, and establish time frames for transferring the approximately 2,600 loan conversions currently with other loan servicers.

Agency: Department of Education
Status: Open

Comments: In its initial response, Education noted it has already taken steps to implement this recommendation, such as a comprehensive assessment to identify the causes of the conversions and the grants affected. After identifying the reasons, the agency worked with current grant servicer to ensure accuracy and make sure they understood program requirements. Regarding time frames for transferring the converted loans, in September 2017, Education provided documentation that the loan conversions were transferred to one servicer in December 2014. In 2018, Education provided additional information on the comprehensive assessment it conducted including the results, a work plan to address the erroneous conversions, and sample letters to recipients they deemed eligible for reconversion. Two changes, however, are currently underway which could affect past and future erroneous conversions. In December 2018, Education announced a process for grant recipients to request reconsideration if their grant was converted in error. Additionally, in 2018, Education's Negotiated Rulemaking Committee began discussing TEACH Grant requirements and ways to reduce and correct the inadvertent conversion of grants to loans, among other things. In April 2019, the subcommittee reached consensus on the proposed rule language, which allowed for erroneous loan conversions to be reversed under certain conditions. As of November 2019, Education has not yet published proposed rules for the TEACH Grant program, and it is unclear the extent to which all eligible recipients will be provided adequate opportunity to have the errors corrected. Given the substantial and ongoing changes to the program administration this recommendation remains open.