60 Day Comment Response

Carl D. Perkins Career and Technical Education Act of 2006 (Perkins V) 

Perkins V State Plan Guide Information Collection Request 

(OMB Control Number 1830-0029) 

Responses to Public Comments Received During the 60-Day Notice 

On April 9, 2025, the U.S. Department of Education (ED) published for public comment, for a period of 60 days, revisions to two information collection requests (ICRs) associated with the Carl D. Perkins Career and Technical Education Act of 2006 (Perkins V): (1) the Perkins V State Plan Guide (1830-0029), which solicits State plans from States; and (2) the Consolidated Annual Report (CAR) (1830-0569), which collects financial and performance information from States that receive Perkins V funds. 

 

We received one (1) comment that was directed to both the Perkins V State Plan Guide (1830-0029) and the Consolidated Annual Report (CAR) (1830-0569) and one (1) comment that was directed only to the CAR. For the convenience of readers, we address all the comments, broken out by topic, received on the State Plan Guide and the CAR ICR in both 60-day comment response documents.  We note that the proposed State Plan Guide and the CAR ICR revisions included identical proposed data specifications for the numerators and denominators of the core indicators of performance described in section 113 of Perkins V. 

Overall Support for ICR Changes

1. One commenter expressed strong support for the Department’s decision to rescind the changes to the State Plan Guide and CAR ICR. The commenter shared that the reinstatement of the previously OMB-approved State Plan Guide and CAR ICR will preserve the stability, flexibility, and clarity needed to effectively implement Perkins V while avoiding costly, time-consuming changes.

Response: The Department agrees that reinstating the previously OMB-approved State Plan Guide and CAR ICR will eliminate undue burden on states and local recipients and empower them to focus their efforts on the effective implementation of CTE programs.

Changes: None

Defining Key Terms in Perkins V

2. One commenter expressed concern that elimination of the requirement for States to provide definitions of “size,” “scope,” “quality,” high-skill,” “high-demand,” and “meaningful progress” would make cross-state comparisons impossible. The commenter also expressed that elimination of this requirement would undermine policy-makers’ and the public’s ability to assess whether Perkins V is meeting its intended goals.

Response: The Department appreciates the commenter’s interest in promoting consistency across states and supporting cross-state comparisons. However, the Department does not agree that requiring states to submit definitions for these terms through the CAR ICR is necessary or appropriate. While sections 113 and 114 of Perkins V require states to report annually on performance and outcomes, the statute does not require states to provide formal definitions for these terms “size,” “scope,” or “quality” as part of their reporting. Requiring states to submit these definitions would impose an unnecessary administrative burden which would redirect time and resources away from the essential work of implementing and improving career and technical education programs. Additionally, requiring states to establish these definitions risks limiting the flexibility states need to design programs that reflect the unique needs of their local and regional economies. This flexibility is a central feature of Perkins V’s accountability framework, and the Department believes it is critical for achieving the law’s goals.  States have developed high-quality CTE programs that are of appropriate size, scope, and quality absent the requirement to formally establish definitions for these terms and to submit them to the Department. Finally, the previous administration’s action to require states to establish these definitions through an information collection process was inappropriate and circumvented the notice-and-comment rulemaking process.

Changes: None

Numerator and Denominator Specifications for the Core Indicators of Performance

3. One commenter expressed concern with the elimination of numerator and denominator specifications for the core indicators of performance under Perkins V. The commenter went on to express that this change would reduce transparency in how states calculate core performance indicators, reduce alignment with the Every Student Succeeds Act (ESSA), and reduce the comparability of data across states.

Response: The Department appreciates the commenter’s interest in promoting transparency, alignment with ESSA, and cross-state comparability. However, the Department does not agree that retaining the numerator and denominator specifications for the Perkins V core indicators of performance is appropriate or necessary. While Sections 113 and 114 of Perkins V establish a state performance accountability system and require states to report on core indicators of performance, the statute does not prescribe specific numerators and denominators to be used in making these calculations. The statute does, however, clearly articulate alignment with ESSA. Requiring states to utilize the numerator and denominator specifications will not materially improve this alignment. Eliminating these specifications will help avoid disrupting the longitudinal data states have been collecting since the inception of Perkins V. In addition, the reinstatement of the previously OMB-approved CAR ICR will still require states to report the numerators and denominators used to calculate performance. This will allow the Department to provide targeted technical assistance and oversight to ensure compliance with statutory requirements, without imposing an unnecessary administrative burden on states and local recipients. The Department believes that this approach appropriately balances transparency and accountability with flexibility and efficiency.

Changes: None

Additional Data Disaggregation

4. One commenter expressed concern with the elimination of additional data disaggregation related to secondary post-program placement (3S1) and postsecondary placement (1P1). The commenter stated that this change would represent a “lost opportunity to understand how different student special populations – particularly students of color, students from low-income backgrounds, and students with disabilities – experience varying outcomes in CTE programs.”

Response:  The Department does not agree that requiring additional disaggregation is necessary to understand the outcomes of different groups of students in CTE programs. Under Sections 113(b)(3)(C)(ii) and 114(b)(4)(C)(ii)(I) of Perkins V, states are required to disaggregate data for each of the core indicators of performance, including secondary post-program placement (3S1) and postsecondary placement (1P1), by special populations and other student categories identified in statute, such as gender and race and ethnicity. These provisions ensure that states and the Department can identify gaps in performance and act where needed. Perkins V does not require disaggregation beyond these categories. Moreover, further disaggregated data would likely not be available from all states, thus limiting its usefulness for national analysis. Imposing this requirement would also create additional and unnecessary administrative burden and costly disruption to existing data systems, diverting state and local resources from direct support for CTE program implementation. As such, the Department has determined that eliminating the additional reporting requirement is appropriate and consistent with both the letter and intent of Perkins V.

Changes: None.

Industry-Recognized Credentials

5. One commenter expressed concern with the elimination of the requirement to describe how certificates and certifications counted for indicators of performance 5S1 and 2P1 are determined to be “industry-recognized” by an eligible agency and what methods, if any, are used to disseminate this information to eligible recipients. The commenter believes the loss of this information would undermine efforts to align CTE with labor market needs and demonstrate the value of the program.

Response: The Department does not agree that this additional narrative information is necessary to ensure that CTE programs are aligned with labor market needs or to demonstrate the value of the Perkins V program. Under section 134(c) of Perkins V, eligible recipients must complete a comprehensive local needs assessment (CLNA) not less than once every 2 (two) years, which requires a description of how career and technical education programs offered by the eligible recipient are, among other things, aligned to state, regional, Tribal, or local in-demand industry sectors of occupations. Section 113 of Perkins V contains substantial accountability provisions that provide robust performance data that are used to determine the value of the program. Additional reporting requirements would create an unnecessary administrative burden, diverting state and local resources from direct support for CTE program implementation.

Changes: None

Middle Grades Data Collection

6. One commenter expressed concern with the elimination of the requirement to report middle grades CTE participation data, when available. The commenter noted that elimination of this data collection would eliminate the “ability to identify early interventions that promote equitable access to high-quality CTE pathways.”

Response: The collection of middle grades CTE participation data is not required under Perkins V. Additionally, the Department does not agree that the collection of this data is necessary to promote access to high-quality CTE pathways. The Department also believes that this data would have little utility given that many states are not able to report it. Finally, states seeking to meet this new reporting requirement would have to make significant and costly updates to existing data systems, diverting state and local resources from direct support for CTE program implementation.

Changes: None

7. One commenter said that the increased administrative burden is an insufficient justification for the Department’s decision to reinstate the previously OMB-approved State Plan Guide and CAR ICR. The commenter went on to state that the elimination of the additional reporting requirements will allow the following “fundamental problems in CTE data collection” to persist: (1) wide variability in how states define and measure core elements of Perkins V; (2) lack of comparability in performance data across states; (3) insufficient data to identify and address equity gaps; and (4) limited understanding of CTE’s long-term impact on student success.

Response: The Department is seeking to reinstate the previously OMB-approved State Plan Guide and CAR ICR for multiple reasons. First, during the public comment periods for the most recent iterations of the State Plan Guide and CAR ICR, the Department received letters and feedback from the CTE community, an overwhelming majority of which were in opposition to the revised ICRs. Following the publication of the final information collections, the Department continued to receive opposition from states, high schools, and community leaders, as well as public officials, raising significant concerns about the impact of the ICR revisions on states and local programs. Second, the Department believes that the recently approved State Plan Guide and CAR ICR would be massively disruptive and result in significant state and local level administrative burden by requiring states to revise their performance indicators and resubmit their state plans right after the most recent four-year planning process. While the previous administration noted only nominal increases to administrative burden because of the revisions, the Department recognizes that significant additional burden that was not considered would divert precious time and resources at the state and local level from direct support for CTE program administration. For example, Department estimates did not include local burden, estimated by some commenters to be upwards of 1000 hours, or the full scope of burden associated with updating performance targets to align with the numerator and denominator specifications. Third, the revised State Plan Guide and CAR ICR would reduce data quality by requiring local grantees to track and obtain data in new and different ways, negatively impacting their ability to utilize trend data to improve CTE programming at the local level. Finally, while the Department acknowledges the importance of measuring performance outcomes to ensure federal funding supports high-quality programs, the action taken through the State Plan Guide and CAR ICR revisions by the previous administration was beyond the legislative language included in Perkins V and it was inappropriate to use an information collection process to essentially foist new regulatory requirements on states and local communities in order to participate in the Perkins program.

The Department disagrees with the commenter’s assertion that “fundamental problems in CTE data collection” persist. Section 113 of Perkins V establishes clear indicators of performance that states must report annually for all CTE concentrators. A review of numerators and denominators submitted by states annually as part of their CARs showed that most states were reporting in a manner consistent with Perkins V. Only a few states appear to have slight issues with their reporting of indicators of performance and the Department is confident that these can be reconciled through targeted technical assistance rather than requiring wholesale changes to reporting systems across the nation. The Department has also developed multiple tools that allow the public and policymakers to compare performance data across states. First, the Department updates a National Summary and State Profiles available at cte.ed.gov on an annual basis. These profiles allow users to easily compare performance among states and provide necessary context (i.e. numerators and denominators, data notes) to ensure such comparisons are well-informed. Second, the Department makes all performance data available via the Perkins Data Explorer which allows users to run custom reports at the state and national level. Section 113 of Perkins V outlines a robust accountability system that requires substantial reporting of disaggregated enrollment and performance data that is used to identify gaps in CTE participation and outcomes. Local recipients are required to consider this data when completing the required comprehensive local needs assessment under section 134(c) of Perkins V and states must develop action plans to address student subpopulations that performed below expectations when a state-determined performance level is not at least 90% met. Finally, the Department does not agree that the revised State Plan Guide and CAR ICR would improve the understanding of CTE’s long-term impact on student success. Any efforts to change performance data collection should be handled through alternative means not via changes to ICRs resulting in a more federally prescriptive role beyond what is required by law.

Changes:   None

Alternative Approaches 

8. One commenter urged the Department to consider alternative approaches rather than eliminating the additional requirements outlined in the revised State Plan Guide and CAR ICR. Specifically, the commenter suggested maintaining the requirements and supporting states via enhanced technical assistance, phased implementation, technology solutions, and streamlined processes.

Response: The Department appreciates the commenter’s suggested strategies but disagrees that they would be sufficient to offset the undue burden and other negative impacts of the revised ICRs. As always, the Department stands ready to provide technical assistance to states to ensure that they are utilizing Perkins V funds to support high-quality CTE programs at the secondary and postsecondary level. Even with enhanced technical assistance focused on meeting the new requirements, substantial burden would detract valuable state and local resources that are better utilized to improve CTE program implementation. The Department’s implementation timeline for the revised ICRs already utilized a streamlined approach that would phase in requirements, yet we still received substantial negative pushback indicating that the timeline was unreasonable and would require many states to engage in a duplicative planning process outside of the regular 4-year cycle that just ended in Spring of 2024. Finally, the Department already invests heavily in technology solutions that are designed to reduce reporting burden for states. Like states, adjusting our reporting systems to reflect the requirements of the revised ICRs would divert valuable national activities funds from other initiatives that have more promise to improve the quality of CTE programs nationwide.    

Changes: None

Impact on the Most Vulnerable Students

9. One commenter pointed to “gender gaps” in CTE participation and stated that they believed students of color and members of special populations (i.e. low-income, students with disabilities, etc.) would be negatively impacted by the reduced reporting requirements.

Response: The Department believes strongly in the potential for career and technical education to improve the lives of students and to set them on a path toward meaningful careers and economic advancement. States have already undergone tremendous efforts to adjust their policies, programs, and systems to meet the requirements of Perkins V, enabling them to provide robust data so stakeholders may identify and address gaps in CTE participation and performance among student subgroups. Instituting additional, burdensome reporting requirements will not lead toward more students benefiting from valuable career and technical education programs. On the contrary, the additional reporting requirements put in place by the previous administration would divert valuable resources, both financial and human, from improving career and technical education program implementation to providing information that is not statutorily required or necessary. Data reported by states under Perkins V, such as non-traditional program concentration at the secondary and postsecondary levels, already provides rich disaggregated data that can be used to identify gaps in participation and performance. By removing additional, burdensome reporting requirements, the Department is taking steps to ensure that state and local resources can be directed toward analyzing the data that is already available under Perkins V to drive decisions that will improve programs and outcomes for students.

Changes: None

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