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.