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Protecting Student Records and Facilitating Education Research: A Workshop Summary 3 The Value of Education Research Using Student and School Records VALUE OF LONGITUDINAL STUDENT RECORD DATA FOR RESEARCH Jane Hannaway (Urban Institute) directs the Center for the Analysis of Longitudinal Data in Educational Research (CALDER), funded by the U.S. Department of Education’s Institute of Education Sciences.1 She described four features of state education databases that make them particularly valuable for analysis and research. First, because they include unique student identifiers, the databases allow researchers to link individual education records over time in order to develop measures of individual learning gains. Researchers can use these measures to eliminate many confounding variables. In the past, investigators sometimes compared student achievement in a classroom at two different points in time, but the classroom might be made up of different students at the later point in time. Perhaps more importantly, these data allow researchers to address the greatest threat to the validity of many educational studies—the fact that students are not randomly assigned to classrooms and schools. Investigators can use the individual measures of academic achievement and other student characteristics in these databases to statistically adjust for the lack of random assignment. Second, Hannaway said, some state databases include unique teacher identifiers that allow researchers to link teacher records with student records and track patterns over time. This feature of the databases has 1 See http://www.caldercenter.org/.
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Protecting Student Records and Facilitating Education Research: A Workshop Summary allowed CALDER research teams to demonstrate the effect of the teacher on student learning and show how widely individual teachers vary in stheir effectiveness. This feature has also enabled research on the factors that may account for the variation in teacher effectiveness, such as credentials, training, classroom behavior, and experience. Hannaway argued that these studies are important because they help to clarify which factors do indeed promote student achievement, which in turn has implications for cost efficiency. For example, many school districts provide higher salaries to teachers with master’s degrees, but recent CALDER studies indicate that, among elementary school teachers, the presence or absence of a master’s degree does not affect student learning gains. Third, the databases consist of census data, including all students and teachers in the state public education system. This feature of the databases allows an investigator to conduct multiple comparisons. For example, in her recent study of Teach for America teachers in North Carolina, Hannaway was able to compare Teach for America teachers with other new teachers, with all teachers, and with fully licensed and credentialed teachers. She described the potential of the databases for multiple comparisons as “very important” for policy purposes and as a valuable complement to random assignment studies. Fourth, the databases incorporate historical records, a feature that is critical to understanding the effects of a change in education policy. For example, when studying Florida’s A Plus accountability policy, Hannaway expected that the policy would have its largest effects on the lowest performing schools. Contrary to expectations, she initially found that the low-performing schools were less likely to change their behavior than the high-performing schools—suggesting that the accountability policy was not working as intended. However, after analyzing additional data from an earlier period, when another policy targeted many of the same low-performing schools, they concluded that the previous policy had already generated behavioral change in the low-performing schools. Without the historical data, Hannaway said, “you could come to a very faulty inference … in policy research.” In response to a question, Hannaway said that the quality of district and state data varies. For example, one North Carolina school district employing a large number of Teach for America teachers provided her research team with data, after a long delay. When Hannaway compared these data with a separate list provided by Teach for America, she found an overlap of only 25 percent. In contrast, some states, including North Carolina and New York, have invested in their data systems, are working with multiple researchers, and have accurate, reliable data, she said.
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Protecting Student Records and Facilitating Education Research: A Workshop Summary USING LONGITUDINAL STUDENT RECORD DATA IN HIGHER EDUCATION RESEARCH Tom Bailey (Columbia University) explained that, as director of both the Community College Research Center, which often analyzes longitudinal student record data from state databases, and the National Center for Postsecondary Research, which conducts more time-consuming and expensive random assignment studies, he sees the value of both approaches. He asserted that it was impossible to carry out “meaningful analysis of student experiences in higher education” without longitudinal data from student records, and that the lack of such analyses limits understanding of higher education. He and other researchers would like to be able track students across higher education institutions in order to address such critical questions as whether community colleges are successful in preparing students to transfer to four-year colleges and how well elementary and secondary schools prepare students for higher education. They would also like to track students within higher education institutions. Bailey observed that the Family Educational Rights and Privacy Act (FERPA) is only one of several barriers that stand in the way of using education records for these types of analysis. One barrier is the fact that, until recently, most people had faith in the quality of U.S. higher education. Because colleges were assumed to be effective, public debates focused on access, rather than on the quality of higher education. Second, because public funding is based on enrollments, community college administrators often define success in terms of current enrollments, rather than thinking about how to improve student success over the course of their college years. Third, increasing student mobility poses a challenge to measuring the performance of individual higher education institutions. Bailey likened policy makers’ current focus on accountability in higher education without attention to individual student progress to General Motors examining its performance without gathering data on car sales over time. National longitudinal databases maintained by the National Center for Education Statistics have yielded valuable knowledge and understanding of student progress in higher education, Bailey said. The Center’s National Education Longitudinal Study of 1988 (NELS 88) collects and maintains data on students over time, including their college transcripts, providing the source for many published studies. However, the data come from limited national samples of all students, including a smaller group of about 1,000 to 1,500 students who have ever attended community college. Given the small size of the national community college sample, it is impossible to analyze student progress in a single state, in demographic subgroups, or in a single educational institution. In contrast, the state
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Protecting Student Records and Facilitating Education Research: A Workshop Summary longitudinal databases, which include records on every student, are much larger, allowing the Community College Research Center to conduct studies of single colleges, subgroups, and other important topics. Bailey expressed surprise at how rarely community colleges analyze their own internal student records. Many of the 83 colleges participating in the Achieving the Dream project lack information on such questions as how many and which type of students succeed in developmental education and go on to take regular college courses. Although FERPA poses no barrier to a college in analyzing the progress of its own students, weak information technology (IT) systems pose significant barriers. Community college IT systems are designed to track enrollments once each year and to send these data to the state for reimbursement, rather than to track individual students over time. Although some states and colleges are trying to improve their IT systems, many do not place a high priority on analysis of student progress. According to Bailey, members of community college boards do not understand what kinds of research could be conducted using student records and how that research might improve their educational programs. Studies using longitudinal data to track student progress over time have already yielded important insights, because they allow researchers to track student responses to educational interventions over long time periods, Bailey observed. For example, a study in Ohio (Purnell and Blank, 2004) found that guidance counseling had strong positive effects on student success in the first two semesters of community college, but these effects had vanished two years later. Studies of developmental education in Florida (Calcagno and Long, 2008) and Ohio (Bettinger and Long, 2008) found that taking these remedial courses had little effect over three years, but greater effects over six years. In another analysis, the Washington State Community College Board found that less affluent students tended to enroll in occupational programs, while their more affluent counterparts more often enrolled in prebaccalaureate transfer programs. The board took these findings to the state legislature and won approval for community colleges to offer applied bachelor’s degrees and for expansion of transfer programs. In another example, Bailey presented an analysis of student progression in mathematics developmental and gatekeeper courses at a single institution. Among students assigned to developmental mathematics courses, 34 percent never enrolled and another 13 percent completed a course but never enrolled in the following gatekeeper course. This kind of information can be surprising to community college leaders, who often focus on improving instruction in individual courses without considering how to ensure that students actually attend classes they are assigned to. In the few states whose longitudinal databases link elementary and
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Protecting Student Records and Facilitating Education Research: A Workshop Summary secondary school records with higher education records, it is possible to assess the effectiveness of K-12 education in preparing young people for higher education. A 2006 survey (Ewell and Boeke, 2006) found that only 11 state databases included these links, slowing research on this important topic. For example, dual enrollment programs, in which high school students may take college courses, are growing rapidly, but little research is available on their effectiveness. The Community College Research Center has done a preliminary study of dual enrollment in Florida, because it has one of the few databases with linked records for K-12 and higher education. Bailey argued that it is also important to link student data among colleges, in order to assess community colleges’ effectiveness in preparing students for transfer to four-year colleges. More broadly, the increased mobility of all college students makes linked data across colleges crucial for any analysis of higher education outcomes. Without such linked data sets, education officials must rely on weak measures, such as the Graduation Rate Survey. This measure, which includes only full-time students, is a weak indicator of community college outcomes, since 66 percent of community college students enroll part-time. In addition, the survey excludes transfers and students who register in the spring, and it tracks students for only three years. To measure community college outcomes more accurately, Bailey and colleagues analyzed longitudinal data on individual college students from the National Center for Education Statistics’ Beginning Postsecondary Students study. They found that, although only 22.9 percent of students graduated from the institution at which they initially enrolled within three years, nearly 46 percent graduated from either their original institution or another institution after six years. State education databases allow development of much more flexible accountability measures, in Bailey’s view. For example, his center has analyzed three- and six-year graduation rates for different groups of students, including transfer students and part-time students, at Florida’s 28 community colleges. While improved accountability measures are important, Bailey said, the real value of the state databases is in allowing more comprehensive and sophisticated analysis of student progress. In conclusion, Bailey reiterated that research on higher education faces many barriers besides FERPA. Individual colleges and state higher education systems could potentially conduct a great deal of valuable research, but this will require a change of priorities, improvement in their IT systems, and increases in their analytic capabilities. While acknowledging that his center wants to build partnerships with the states, bringing its skills and research priorities, he said it was critically important to increase the states’ own skills and priorities.
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Protecting Student Records and Facilitating Education Research: A Workshop Summary Responding to a question, Bailey said that Florida and Washington are among the very few states that have linked employment data with education data in their longitudinal databases. For example, researchers analyzing linked data in Washington found that, among community college students who took adult basic education courses, those who continued in other courses and completed least 30 credit hours earned more money later than those who completed fewer credit hours (Prince and Jenkins, 2005). On the basis of this research, the state created a new program integrating adult basic education and occupational skills training. BENEFITS OF RESEARCH ACCESS TO LONGITUDINAL STUDENT RECORD DATA Susanna Loeb (Stanford University) opened by discussing how FERPA affects university-based researchers’ access to data from individual student records. She said that FERPA allows an education agency to share personally identifiable information from student records without written consent if the disclosure is to “organizations conducting studies for, or on behalf of, educational agencies or institutions for the purpose of … improving instruction.” The study must be conducted “in a manner that does not permit personal identification of parents and students by individuals other than representatives of the organization” (U.S. Code, Title 34, Part 99, Section 31.6). While this provision has allowed valuable research in education policy and practice, Loeb said, it has been interpreted in very different ways. Some schools and education agencies have shared data, while others have not. In her view, the difficulty of interpreting the law has required both researchers and school personnel to expend substantial effort on compliance. Addressing the question of why an education agency might want to give researchers access to its data, Loeb said that education policy makers often seek research evidence to inform their decisions. However, most school districts and state departments of education have quite limited capacity to conduct research. Researchers at universities and think tanks can provide the time and some of the expertise needed to make the best use of the information that education agencies have. In addition, outside researchers often have the flexibility to look at medium-run and long-run questions that do not help as directly with day-to-day decisions but can inform better decisions in the future. The first benefit of allowing access is that researchers have time to compile and analyze data, Loeb said. Because linking and cleaning data from multiple sources is time-consuming, very few states and school districts have done so. For example, she belongs to a team of researchers studying the teacher workforces of New York City and New York state,
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Protecting Student Records and Facilitating Education Research: A Workshop Summary who have obtained, compiled, checked, and cleaned data from over 10 different sources. From New York public schools, the team obtained data on student demographics and test scores and teachers’ years on the job. From New York state, they obtained data on individual teachers, including whether they were certified, their scores on the certification exam, and which teacher education program they had completed. In addition, the team identified the institutions from which individual teachers earned their undergraduate degrees and combined this information with the Barron’s ranking of college selectivity to construct variables measuring the selectivity of the college from which each teacher graduated. While the research team had time to devote to this process, it is unlikely that any single education agency in New York would be able to compile all of these data sets. FERPA protections apply both to the individual student data and also to the individual teachers when they were students. Dedicating this time to accessing and compiling data sets, Loeb said, has allowed her team to conduct several important studies, including an analysis of the impact of the No Child Left Behind Act provision requiring school districts to employ only “highly qualified teachers.” In response to the law, the New York City Department of Education eliminated emergency certified teachers between 2002 and 2004, replacing them with teachers prepared by alternative certification programs, including Teach for America and New York City’s Teaching Fellows Program (see Figure 3-1). As a result of this change, the average math SAT scores of teachers in the poorest schools increased dramatically. Today, the poorest schools employ higher scoring new teachers than the richer schools. The second benefit of allowing access is that researchers provide expertise. Although school district and state personnel can often answer day-to-day questions by providing accurate, timely descriptive statistics, outside researchers are able to analyze longitudinal data in much more sophisticated ways. They conduct value-added analyses to assess how much various factors contribute to student learning over time and difference-in-difference analyses to compare patterns in two different time periods. Outside researchers also use a variety of techniques for simulating experiments. In addition, they are using longitudinal data and “putting experiments on top of them,” Loeb said. After randomly assigning students or schools (or both) to treatment and control groups, Loeb said, the researchers are not required to gather survey data from the two groups, relying instead on the data that are collected on an ongoing basis in a state or school district database. Loeb offered two examples of important findings resulting from outside researchers’ expertise. First, her team used value-added modeling of longitudinal data to estimate the effect of the “highly qualified teacher” requirement on student achievement (Boyd et al., 2008). They found that
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Protecting Student Records and Facilitating Education Research: A Workshop Summary FIGURE 3-1 Number of new teachers in New York City by pathway, 2000-2005. NOTE: TFA = Teach for America. SOURCE: Boyd et al. (2008: Figure 6). the largest increases in teacher effectiveness were in low-income schools, where the weakest teachers were eliminated, whereas the policy had little impact on teacher effectiveness in the richer schools. These improvements in teacher qualifications in the poorest of schools reduced the gap between rich and poor schools in student achievement by 25 percent (see Figure 3-2). Second, she described studies by Jacob and Lefgren (2004, 2007) of a policy introduced in Chicago public schools requiring students scoring below a specific cut score on a reading and mathematics test to be retained in grade. The researchers used regression discontinuity analysis to compare quite similar students whose scores were below and above the cutoff score—an improved approach over previous studies, which often simply compared the academic achievement of students who were retained with the achievement of other students who were not. In contrast to previous studies, which generally have found that retention has a negative effect on student achievement, Jacob and Lefgren (2007) found increases in measured academic achievement one year later among students who were retained in third grade. However, in comparison to students not held back, these gains vanished by the time the students reached sixth grade. The third benefit of sharing student record data with outside researchers is that researchers’ broad perspective allows them to address questions relevant to long-run policy. For example, Boyd et al. (2005) combined data from college applications to the State University of New York with information from the College Board to describe how close to home teachers
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Protecting Student Records and Facilitating Education Research: A Workshop Summary FIGURE 3-2 Effect of all observed teacher qualifications on students in grades 4 and 5 mathematics achievement, most affluent and poorest deciles of schools, 2001 and 2005. SOURCE: Boyd et al. (2008: Figure 8). tend to teach. They found that most public school teachers in New York take their first public school teaching job very close to their hometowns or to where they attended college. Teacher candidates coming from suburban or rural hometowns strongly prefer to remain in those areas, rather than teach in urban districts. Their findings have particular implications for the long-term policies of urban districts, which are net importers of teachers. The study suggests that urban districts must offer salaries, working conditions, or student populations that are more attractive than those of the surrounding suburban districts to attract sufficiently qualified candidates. The broad perspective that outside researchers bring to education questions is apparent in studies that yield important policy information for more than one education agency. For example, an analysis conducted as part of the study of New York City teachers (Boyd et al., 2005) identified differences in the effectiveness of various teacher education programs, as measured by student achievement. The study also identified features of teacher preparation programs associated with greater gains in student
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Protecting Student Records and Facilitating Education Research: A Workshop Summary achievement—such as providing preparation for teaching practice and developing knowledge of content areas. These findings have implications for other organizations—specifically, colleges providing teacher education—as well as for the New York City Department of Education. Despite these important benefits to education agencies that share data, Loeb said, researchers often find it difficult and costly to gain access to education data sets. She asserted that the many local school districts, states, and higher education institutions that are interpreting FERPA lack clarity about how to comply. As a result, people in each organization have to think about compliance before providing access. For example, Loeb said, the research team studying the New York state and city teacher workforces had to obtain approvals for the research from over 20 different state and local education agencies and higher education institutions. Obtaining approval from the institutional review boards at 18 different colleges and universities engaged in teacher preparation was nearly a full-time job for one member of the research team, and compiling the data took all of another researcher’s time. The process led to a different data-sharing agreement with each organization. The team has a contract to act as an agent of New York State and has signed memoranda of understanding with many school districts across the country, each of which is slightly different from the others. A few districts do not want a formal memorandum of understanding but require the research team to fill out a form. This process has “huge time costs,” Loeb said, partly because schools and agencies are nervous about complying with FERPA. For example, although her workshop paper (Loeb, 2008) includes sample language from a memorandum of understanding with one school district, most of the school districts were unwilling to publicly share their memoranda, because of uncertainty about compliance. Another result of the process is that researchers must work with incomplete and unrepresentative data, because agencies that do not want to share their data use FERPA as an excuse not to provide them. Even agencies that are willing to share data sometimes do and sometimes do not, depending on how much time they have and whether they know and trust the researchers. Ultimately, Loeb said, the extent of data sharing depends on researchers’ ability to develop trust with individual education officials and analysts, which has benefits. For example, her research on the New York teacher workforce was strengthened by extensive discussions with city and state officials. She explained that she is able to access other data from other school districts because she is part of a group at Stanford that gives executive training to superintendents from around the country about the benefits of sharing data with researchers. The bottom line, Loeb concluded, is that there would be benefits to making FERPA “a little bit more understandable” to school districts and state departments of education.
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Protecting Student Records and Facilitating Education Research: A Workshop Summary She said that the National Center for Education Statistics’ data licensing system was a good model for protecting confidentiality while also providing access. Although the protections are much stricter than those included in her team’s contracts and memoranda of understanding with other organizations, it is “much, much easier and less time-consuming for us” to comply, because there is a manual to follow. VALUE OF RESEARCH PARTNERSHIPS Barbara Schneider complimented the speakers, observing that CALDER was doing “the most important work on the state longitudinal databases that we have” and that no one was conducting the kinds of analyses of community college education that Bailey’s group was undertaking. However, she expressed deep concern about the value and importance of education research. Observing that none of the states has the time or analytic capacity to carry out the types of studies described by the panelists, she said that the real barrier to increased access to state data has been that the researcher has gone in, taken the state’s data, and then the state officials never hear from the researcher again—leading to negative feelings about researchers. Schneider called on researchers to establish a new form of relationship with state education officials, including the ideas not only of researchers, but also of the state, and emphasizing the shared interests of both parties. Praising Loeb’s “spectacular” research, Schneider said its results are important, particularly the finding that, at the high school level, the alternative certified teachers are more effective than traditionally prepared teachers, as measured by student achievement. The real question, she said, is what will happen when Loeb and colleagues publish these findings, which reflect negatively on the traditional teacher education institutions that provided data to Loeb’s research team. She asked how researchers can go back to agencies and institutions with which they have signed memoranda of understanding to discuss findings that may be negative and, if so, whether the agencies or institutions might pressure the researchers not to publish such findings. She asked about the long-term implications, particularly in light of her call for a new relationship between researchers and education agencies. Loeb responded that she has observed a change in the way her team interacts with New York City school officials. Five years ago, she said, no one wanted to know about any weaknesses in the teacher workforce, but today all school officials want information on their teachers’ “fixed effect” on student achievement, are happy to share that information with the city, and want to know how they can do better. She said that, as university-based researchers, her team retains control over the research information
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Protecting Student Records and Facilitating Education Research: A Workshop Summary and will publish it. At the same time, however, education officials are likely to recognize errors in the team’s data or in its interpretation of the data. Recognizing the value of this expertise, Loeb’s team shares draft papers with agency officials, allowing them 30 days to comment, a process she described as “good for them and for us.” Bailey said Schneider had raised a potentially serious issue, as it can create problems if researchers find that an existing policy is ineffective. His team, too, shares draft papers with state officials and discusses the drafts before publication. He said he believes that, in some cases, continued access to data has been limited because of studies reaching negative conclusions and described this as an ongoing problem. However, he emphasized that good access to state education data often is the result of long-term investments by a few states. For example, Florida has held a three-day conference annually for the past 20 years, including all those responsible for sending data into the comprehensive state database, to discuss technical issues. Similarly, the state of Washington has a very good database on community colleges that has been developed with strong political support over 15 years. These states not only have better quality data but also have easier relationships with researchers when discussing such issues as negative findings about education policies. Bailey suggested supporting sustained state efforts like these. Hannaway noted that, when accepting a grant or contract from an education agency, CALDER always retains the right to publish research results but is flexible about when to publish. The center tries not to blindside education agencies that have provided longitudinal data. In addition, the researchers try not to prejudge educational programs that are still at an “incubator stage.” The researchers take time to develop trust with education agencies and to ensure that the researchers fully understand the policy or program they are investigating. Helen Ladd (Duke University) said that, although researchers involved in establishing the North Carolina Education Research Data Center developed trusting relationships with the state and school districts, the center now makes the data sets available to outside researchers, both inside and outside North Carolina. This could have drawbacks if an outside researcher conducted a weak study that would put the North Carolina Department of Education on the defensive. Felice Levine observed that these concerns about publishing negative results, while very important, represented a dimension of conducting responsible, ethical research that is not specific to FERPA. Focusing more specifically on FERPA, Levine observed that access to personally identifiable student record data is often provided without requiring written consent under the law’s exception for studies conducted “for, or on behalf of,” an education agency. She asked whether contracts between researchers and agencies reflecting this provision of the law
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Protecting Student Records and Facilitating Education Research: A Workshop Summary always protect researchers’ autonomy to publish their findings. Loeb responded that her team’s memoranda of understanding do guarantee the right to publish, as required by the team members’ universities. Bailey expressed the view that researchers’ right to publish can be guaranteed in the language of the contracts they negotiate, but the real question was whether researchers would be allowed further data access after publishing negative findings about a state or district. His center’s researchers have sometimes encountered problems when an individual staff member with whom they have developed a relationship leaves the agency, which has sometimes led to limits on access or lengthy delays before approval of the next data request. A member of the audience suggested that the take-home message of the panel, including the examples of successful research, was that FERPA and the Common Rule were “really not much of a problem” for researchers. Hannaway disagreed, saying that it was important not to underestimate the costs of obtaining access to these data sets and the “tenuousness” of the relationships researchers had established with states and school districts. Martin Orland (WestEd) asked whether there were cases in which researchers had tried to gain access to data but FERPA posed a barrier. Hannaway said this had happened in Texas: John Kain, at the University of Texas at Dallas, established relationships and negotiated data-sharing agreements with the state and local school districts, which included confidentiality protections in compliance with FERPA, in the Texas Schools Project. With support from the Spencer Foundation, Kain’s team compiled these and other data from multiple sources into a comprehensive longitudinal database with individually linked records on K-12 and higher education and employment outcomes (Kain, 2000). Analyses using the database yielded important findings about student achievement gaps (Kain and Singleton, 1996) and teachers in Texas (e.g., Hanushek, Kain, and Rivkin, 2004). However, Hannaway said, a change in the state’s interpretation of FERPA led it to block access to more recent data (Hanushek, 2007). Although the researchers made several efforts to obtain renewed access, including an appeal to the state legislature, they were unsuccessful.2 Describing the state’s decision as “arbitrary,” Hannaway called for central guidance on how to interpret FERPA. Marilyn Seastrom said that the value of developing trusting relation- 2 The University of Texas at Dallas has recently established a state-designated Education Research Center in collaboration with the Texas School Project. According to its website, the new center will assemble, clean, and document deidentified K-12 and higher education data for analysis by the center and will also facilitate secure use by outside researchers in compliance with FERPA (http://www.utdallas.edu/erc/about/ [accessed July 2008]).
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Protecting Student Records and Facilitating Education Research: A Workshop Summary ships with the states is not unique to outside researchers. National Center for Education Statistics analysts who create the central core data always send the data for each state back to the state where it originated. This is done partly to verify and edit the data, but also so that the state department of education knows in advance what information will be made public. The center has an “elaborate process” of keeping state education officials involved and informed. Shelly Martinez (Office of Management and Budget) agreed with Seastrom that these issues of data access are not unique to university researchers. She explained that she participates in the Federal Committee on Statistical Methodology, whose members discuss the use and confidentiality of administrative records across all federal agencies.3 Martinez observed that there are confidentiality laws similar to FERPA in every field, including health care, in which HIPAA protects individual health records. She said that federal statistical agencies need clear guidance on how to interpret these laws across a variety of situations, because federal agencies are often “in just as tenuous a situation as many of you” when they seek access to state or federal administrative data. Based on her monthly discussions with federal analysts studying nutrition, income, and other topics—all of whom face similar challenges—she suggested developing broad, systematic solutions, as well as addressing the more specific data access challenges posed by FERPA. In conclusion, Ladd observed that it is important to remember that access to data is sometimes limited by technical weaknesses in state IT systems, not only by FERPA. 3 See http://www.fcsm.gov/committees/cdac/.