Depending on the magnitude of the crisis, tracking students for funding and accountability purposes will likely have ramifications on data systems and policies for a long time. Longitudinal data systems are especially vulnerable to disruption when an institution quickly or unexpectedly sees large student population changes—in or out.
Funding. When a large geographical area is affected by a disaster and federal aid is available, new data may be needed to allocate relief funds and other assistance. During these situations, federal agencies usually work directly with affected counties to identify or request needed data. This process is more complicated when school districts are not aligned with county boundaries. In some cases, the LEAs' burden may be reduced if the SEA communicates with the federal agency on behalf of its districts.
Auditing. When accepting federal emergency funds, agencies should anticipate audits of data submitted to verify funding eligibility. Auditors look for duplicate counts of students, confirmation of displaced student status (i.e., an originating school in the area affected by the crisis), and potential fraud. Detailed information about entry and withdrawal dates is critical to ensure redundant requests for funding the same student are not sought or received. After hurricanes Katrina and Rita, federal audits were conducted at the individual student level. To comply with these types of audits, agencies should have student data available in a format that accommodates reasonable audit requirements. These audits can be a burden for agencies, but if high quality data are maintained they should not be a problem.
SEA acting as fiscal agent for LEAsBecause Louisiana had an extensive, statewide Student Information System that included a displaced student identifier, SEA officials worked directly with federal agencies to manage all data requests for Federal Emergency Impact Aid. Having the SEA serve as an agent for its districts has proven to be advantageous during large-scale crises that affect more than one district.
Core data tracking. Following a crisis, routinely reported student data items are generally still required from schools and agencies to meet regular state and federal reporting needs. Clearly, large changes in student populations, such as those seen when numerous students are displaced, may substantially alter the statistical data normally reported by an agency. For example, longitudinal data on student enrollment, program participation, and other measures may fluctuate markedly due to an influx or outflow of displaced students. Explaining these extenuating circumstances in footnotes is appropriate wherever the data are published.
Accountability concerns. A large movement of students in or out of an agency can also influence accountability data. When this occurs, it may make sense to modify high stakes accountability requirements related to test scores, graduation rates, and subgroup membership to reflect the movement of displaced students. For example, most states measure student progress relative to state curriculum standards. Under some circumstances, excluding from testing those students not previously taught in the state may be reasonable. States and districts may wish to seek exemptions from state and federal accountability standards in these situations.
Statewide testing and accountability
With respect to No Child Left Behind (NCLB) requirements for the school year following hurricane Katrina, the U.S. Department of Education sent a letter to all chief state school officers outlining temporary options for states affected by the crisis.
Regarding NCLB's Adequate Yearly Progress (AYP) requirement:
Under both options, states still had to "comply with current NCLB requirements for assessment, accountability, and reporting. All students, including displaced students, (had to) be tested on state assessments, and states (had to) ensure that their policies (helped) schools and districts meet the AYP target of testing at least 95 percent of students."
A copy of the letter, which provides more information on these options, is available online.