–3–
The Federal-State Cooperative Relationship

WITH ITS MANDATE TO COLLECT DATA on vital events, the National Center for Health Statistics (NCHS) shares a common challenge with several of its peers in the highly decentralized federal statistical system: functioning as a national-level collector of information on phenomena that are inherently local in nature. Accordingly, mechanisms for cooperation and coordination between federal statistical agencies and state or local authorities are common in the statistical system, ranging from relatively simple awareness-building activities (e.g., the multitude of short-term partnerships that the Census Bureau forges to boost participation in the decennial census) to highly structured contractual and financial agreements (e.g., the grants administered by the Bureau of Justice Statistics to support development of criminal history record databases).

The Vital Statistics Cooperative Program (VSCP) that has been formed between state and local registration areas and NCHS is, as workshop presenter Ed Hunter (Centers for Disease Control and Prevention) noted, a federated system, with the national or federal-level entity of NCHS providing funding, coordination, and standards, but with the individual states and localities retaining significant autonomy in their operations. The general structure of the system and the special challenges it faces—some challenges common to nearly all federal data collection efforts in a time of scarce resources, but others unique to the nature of the vital records that are the source of data in the VSCP—was a recurring theme at the workshop.



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–3– The Federal-State Cooperative Relationship W on vital events, the Na- ITH ITS MANDATE TO COLLECT DATA tional Center for Health Statistics (NCHS) shares a common chal- lenge with several of its peers in the highly decentralized federal statistical system: functioning as a national-level collector of information on phenomena that are inherently local in nature. Accordingly, mechanisms for cooperation and coordination between federal statistical agencies and state or local authorities are common in the statistical system, ranging from relatively simple awareness-building activities (e.g., the multitude of short- term partnerships that the Census Bureau forges to boost participation in the decennial census) to highly structured contractual and financial agreements (e.g., the grants administered by the Bureau of Justice Statistics to support development of criminal history record databases). The Vital Statistics Cooperative Program (VSCP) that has been formed between state and local registration areas and NCHS is, as workshop pre- senter Ed Hunter (Centers for Disease Control and Prevention) noted, a federated system, with the national or federal-level entity of NCHS provid- ing funding, coordination, and standards, but with the individual states and localities retaining significant autonomy in their operations. The general structure of the system and the special challenges it faces—some challenges common to nearly all federal data collection efforts in a time of scarce re- sources, but others unique to the nature of the vital records that are the source of data in the VSCP—was a recurring theme at the workshop. 35

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36 VITAL STATISTICS In this chapter, we summarize some threads of this discussion on the structure of the VSCP Section 3–A describes the role of the states and, more . generally, the challenge of data collection given the civil registration nature of the underlying birth and death certificates. Section 3–B summarizes the constraints on the vital statistics collection system from NCHS’s perspective as national-level coordinator. Finally, Section 3–C profiles selected models of federal-state cooperation elsewhere in the federal statistical system. Workshop presenters and participants received two background papers prepared at the workshop planning committee’s request: one on the role of the states (prepared by Steven Schwartz, New York City Department of Health and Mental Hygiene) and the second on NCHS’s role. These papers are reprinted in Appendixes A and B, respectively; they have only been min- imally edited for consistency with National Research Council report style. Schwartz gave a presentation at the workshop that closely followed the con- tent of his paper; there was no explicit counterpart presentation of the back- ground paper by NCHS, but several of the paper’s themes were sounded by Jennifer Madans and other NCHS staff (as summarized in Section 3–B). 3–A THE ROLE OF THE STATES Schwartz emphasized the local nature of vital events and the collection of records. At the outset, records of each of the more than 11 million vi- tal events—births, deaths, marriages, and divorces—that occur each year in the United States are processed through one of the more than 6,000 local registrars. These local registrars form a diverse and complex network, and Schwartz’s own local experience offered an interesting perspective on the geographic distribution and the workload of registrars. The state of New York has the most local registrars of any state—about 1,500—yet New York City and its more than 8 million inhabitants have only one official registrar. The New York City registrar’s office alone processes about 500 live births and 160 deaths every day—about 300,000 vital events annually. Records data funnel through the local registrars to the 57, mainly state- level, registration jurisdictions. As already noted, two cities—New York City and Washington, DC—function as registration jurisdictions. (Schwartz ob- served that, at one time, registration districts were more city based and, in fact, New York City began as a registration area before New York state.) Each of the 57 registration jurisdictions reports data directly to NCHS through the VSCP Schwartz also noted another centralizing force in the . system—the National Association for Public Health Statistics and Informa- tion Systems, the professional association of the state vital records offices that was founded in 1933 and works with NCHS and the states on data collection issues.

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THE FEDERAL-STATE COOPERATIVE RELATIONSHIP 37 Schwartz observed that the registration jurisdictions vary considerably in their capacities and individual procedures, their staff size and expertise, and their level of system automation and electronic database implementation. He said it is important to bear in mind that the state and local vital records offices must fulfill three basic—and sometimes competing—roles. Two of these roles have historically dominated the work of the offices: 1. Civil registration of vital events: The most basic function of the vi- tal records offices, the civil registration function of vital events, has the important implication of making the offices huge customer service operations. Schwartz said that walk-in customers have pressing legal needs for records and certified copies and may require corrections or amendments to existing legal documents; as custodians of the records, the vital records offices also have a responsibility to be prompt and responsive. Schwartz noted that his New York City registrar’s office fields on the order of 700 walk-in customers a day, seeking copies of records or other services; the approximately 800,000 paid copies of birth and death certificates that the office issues each year accounts for about $12 million a year in revenue. 2. Public health statistics collection: It is the processing of records data— the information on the birth and death certificates—that ultimately populates the vital statistics data files. Schwartz noted that there is a constant tension in resource allocation between the statistical role and the civil registration and customer service role and that the statistical side must take second place. Yet a third and no less important role has arisen and been made explicit in law in recent years: vital records offices are also front lines in national security efforts. Both Schwartz and Hunter noted that birth certificates have become particularly sensitive because they are breeder documents that are the basis for many other important documents and legal statuses. Birth cer- tificates can constitute proof of U.S. citizenship; because each vital records reporting jurisdiction maintains a contract with the Social Security Adminis- tration (SSA), birth certificates also trigger issuance of Social Security num- bers and eligibility for benefits. Birth certificates are also used to obtain state driver’s licenses and federal passports, key means of establishing identity. The Intelligence Reform and Terrorism Protection Act, which became law in December 2004, was a partial implementation of the recommen- dations of the National Commission on Terrorist Attacks Upon the United States (2004). Among its provisions was a set of minimum standards meant to secure birth certificates. Hunter argued that the changes in the 2004 act were not really new—a 1996 immigration act passed by Congress contained many similar provisions. However, the 2004 act was substantively differ- ent in important ways and carried particular urgency given that several of

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38 VITAL STATISTICS the terrorists in the attacks of September 11, 2001, had obtained passports and identity documents using fraudulently obtained birth certificates. Rec- ognizing the federated nature of the vital registration system—not national or federal per se, and so lacking the ability to directly effect changes—the 2004 bill simply stipulated what the federal government would accept as a valid birth certificate. This left implicit—and up to the states and localities— what changes to the system were needed to meet those standards in order for certificates to be valid for federal purposes. As Hunter summarized, and Schwartz echoed, the demands of this new national security role for vital records offices are considerable: • The 2004 act sought to reduce the hundreds of different variations of birth certificates, including commemorative or ceremonial ones issued by the states, that were previously allowed. The act defined standard, recognizable paper certificates, printed on a certain type of security paper, as well as other provisions for basic structure. • In addition to securing the physical document, the 2004 act’s provi- sions are intended to secure the system by which they are issued. One part of this revised system is a requirement for rapid ascertainment of death certification and a direct matching of death to birth records to preclude fraudulent use of birth certificates of the deceased. Like other background check systems, the critical requirement of this matching is that it needs to cross all jurisdictions and it needs to be fast. However, although the act was signed in December 2004, Hunter’s workshop presentation described “regulations for secure systems” as “pending” and still in progress; NCHS put draft regulations together, but these are still circulating through the federal system. • Although the act’s text only explicitly speaks to standards for birth certificates, the requirement of matching of birth and death records tacitly also implies standards for death certificates. Schwartz noted that the new national security role is one that is resource intensive for localities and, again, one that can blur the states’ ability to fo- cus on the public health data collection role. In discussion, Kenneth Prewitt (Columbia University) noted another way in which the security role poten- tially clashes with the data collection role. He worried that, to the extent that electronic vital registration systems become portrayed as a homeland security tool or even a type of law enforcement mechanism for detecting fraud, complications may arise for statistics. That is, security may become so tight and participation sufficiently strained that it may be more difficult to move the system into the kind of social, public health surveillance system that is needed for detection of early disease or other health incidents. In terms of the functioning of the VSCP Schwartz expressed strong sup- , port for the basic distributed nature of the system. The locally distributed

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THE FEDERAL-STATE COOPERATIVE RELATIONSHIP 39 system of collecting vital event data gives state and local registrars maximum leverage to work closely and directly with their source data providers: hos- pitals and physicians, funeral homes, nursing homes and clinics, and so forth who contribute the information that populates vital records. This approach satisfies local authorities’ need to effectively be the master of their own data stream—to best know their own data and their own data providers. However, he also agreed that it is not a perfect system, and noted several particular challenges: • At the national level, the compiled vital statistics data can only be as timely (and as high quality) as the weakest state. Reporting lags and data quality or consistency issues of an individual state, large or small, can impair the national system. • A related challenge is that the distributed nature of the VSCP makes training, educating, and querying of the source data providers a key aspect of improving and maintaining end data quality, particularly the case for cause-of-death reporting, for which consistency in approach is critically important. However, such training and education efforts are probably the first thing to suffer in a competition for scarce resources. • The individual registration jurisdictions are sensitive to the amount of funds that NCHS provides through the VSCP and uncertainty over , NCHS’s resources can have significant local effects. In discussion, Schwartz commented that New York City’s use of NCHS-provided VSCP funds is principally to pay staff. He noted the example of NCHS’s discontinuation of abortion reporting in 1995, the result of which was that New York City lost more than $75,000 in funding and had to forgo a staff position and active surveillance of abortion providers. Hence, in recent reports, the city has had to attribute drops in the number of abortions to the cessation of active monitoring— rather than a real decline—because its ability to accurately measure activity has been impaired. • A further complication in the distributed nature of the system was sug- gested by then–Census Bureau director Steve Murdock in his luncheon remarks at the workshop, drawing on his experience as state demogra- pher of Texas. In states with extensive rural populations, such as Texas, the county clerks responsible for processing birth and death certificates (not to mention other government documents) may be part-time po- sitions and, hence, data collection and processing (and furtherance of the national vital statistics collection efforts) might not be a high pri- ority. He said that the part-time nature of these jobs contributes to the growing pains that occur as paper-and-pencil registration systems become computerized systems and to the lags that result in some areas.

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40 VITAL STATISTICS Like Hunter, Schwartz commended the development of electronic sys- tems for the automated processing and verification of birth and death records. The system has made great strides in moving away from having the data on paper forms key-entered by local offices; web-enabled systems that permit hospitals and doctors to enter and certify data electronically have the potential for improving data quality and timeliness. The catch, he noted, is that these automated systems carry extremely high start-up costs—on the order of $1 million per death or registration system—that state and local registration offices have had difficulty obtaining from their parent govern- ments. The result—as noted by other workshop presenters—is a lack of uni- form implementation. Schwartz’s paper in Appendix A provides additional details on specific electronic systems that have been developed or proposed, including the national State and Territorial Exchange of Vital Events that is proposed to permit matching of birth and death records across all vital statistics offices. Going forward, Schwartz suggested that it is important for the stake- holders in the VSCP to consider ways to look at the system’s return on investment. He argued that the system is not broken but that there is no clear measure of how good or how bad it is: some estimates of the return on investment of resources at the national and state levels would be valuable for building support for the system among policy makers. He suggested the example of the SSA’s Enumeration at Birth Program (EAB; initiated in 1990) that assigns Social Security numbers to newborns, with parental approval, when a birth certificate record is processed. The SSA Office of Inspector General audited the program (using SSA’s own data) and estimated the av- erage cost of the traditional process—individual parents walking into local Social Security offices to obtain a number for their newborn children—to be $18.70 per record process; in comparison, the audit suggested that the total cost of processing records under the EAB system (including the fee that goes to the states for processing) is only $3.74. As Schwartz noted, the resulting estimate of about $60 million in savings each year (about $15 per record, multiplied by about 4 million births per year) is a clear and compelling assess- ment of the return on investment of the EAB program. Noting that the EAB program might be a relatively easy-to-measure case as a pure administrative system, Schwartz argued that these kinds of figures are worth considering in relation to vital statistics. Measuring the value of vital statistics is consider- ably harder—trying to quantify things such as the value to research of the data files and the returns of the use of locally held vital records data to pop- ulate immunization or lead-exposure registries or to target newborn home visits by nurses. Still, such measures are important to consider in making the overall VSCP better and demonstrating its unique value.

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THE FEDERAL-STATE COOPERATIVE RELATIONSHIP 41 3–B CHALLENGES AND LIMITATIONS AT THE NATIONAL CENTER FOR HEALTH STATISTICS The largest problem facing the current VSCP from NCHS’s perspective was first raised very early in the workshop. Committee on National Statis- tics director Constance Citro observed that the workshop was planned with three Cs as themes: to celebrate the many and growing needs served by vital statistics, to critique the program to identify strengths and weaknesses, and to contribute to a better understanding by policy makers of the value of vital statistics. NCHS director Ed Sondik countered that the third of these Cs could readily be simplified to “costs”—grappling with the continuing chal- lenge of obtaining high-quality data through a cooperative program when both federal and state resources are tight. He commented that in order for the center to balance the agency’s budget, NCHS does not have sufficient resources to fill all of the vital statistics needs. Indeed, he commented that NCHS has been meeting with its Board of Scientific Counselors specifically to discuss options for the programs should NCHS’s generally flat funding continue. The presentation by Jennifer Madans (NCHS) in the final session of the workshop echoed the concern about costs. She observed that the desire to build the vital statistics system and revamp it—including further promotion of electronic systems—is coming at a time when both NCHS and state gov- ernments are facing tight funding constraints. In its planning, NCHS has had to generally assume a flat budget going forward and simultaneously wrestle with the data collection costs for information collections in all other areas in health. Accordingly, she noted a certain level of frustration by all vital statistics stakeholders: there is a strong need for the data and great pride in the vital statistics system, but not a great deal of latitude for massive im- provement in one single program without resources. The sensation is one of striving to meet today’s problems by putting off tomorrow’s problems, which are investments in future capacities: the problem is that sooner or later the VSCP is going to get to tomorrow. From NCHS’s perspective, a constant challenge given the cooperative nature of the VSCP is determining fair shares of costs. As mentioned above, the states and localities must deal with the civil registration aspect of vital events, and the staff and resource allocation to keep up with customer ser- vice is a very significant local administrative focus. The key questions are: What is the cost of gleaning the data from the records and the value of the information that the states and localities possess (both in local totals and compiled national data)? How do those values lead to a determination of who is responsible for what part of the overall costs? In this context, Madans noted that the VSCP is an interesting case in point in the broader federal statistics system. In many agencies and applica-

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42 VITAL STATISTICS tions, she said that a common theme is the use of administrative records and administrative data for several purposes. The argument is that the use of ad- ministrative data will make things different (ideally, better) and will require some changes in interpretation but will almost certainly make things more efficient and less expensive (to the extent that the administrative data are used to reduce field data collection). Vital statistics are commonly pointed to as a long-standing example of such administrative data being used. What is not always appreciated, though, is the synergy that went into the develop- ment of the VSCP In other statistical applications, administrative data tend . to be thought of as records that have been generated and created for a to- tally distinct purpose that can then be tapped at little or no cost and added as part of one’s database. Because of the cooperative nature of the VSCP and the revisions of standard certificates, the system itself develops the form and content of the administrative record. This gives the system great flexi- bility in the content of the data—it is not clear what would be on birth and death records if this cooperative system had not developed—but carries with it significant costs and challenges. 3–C EXAMPLES OF FEDERAL-STATE COOPERATION IN THE U.S. FEDERAL STATISTICAL SYSTEM Two workshop presenters described the general structure of federal-state cooperation within their agencies, to suggest possible improvements in the structure of vital statistics collection. The two specific systems considered in these presentations are of interest because of their parallels to the col- lection of vital statistics. The Quarterly Census of Employment and Wages (QCEW) parallels vital statistics in that the source data are essentially admin- istrative records with other legal purposes (in this case, tax filings to unem- ployment insurance programs); it differs from the vital statistics program in having a strongly defined set of legislative requirements for the structure of the federal-state partnership enacted in recent years. The second example, the Education Department’s Common Core of Data (CCD), parallels vital statistics in that initial responsibility for data completion is diffused among a wide variety of state and local authorities (in this case, individual elementary and secondary schools as well as state departments of education); it differs from the vital statistics in that several of the components of the CCD serve a primarily directory-building role rather than an analytical role. 3–C.1 The Quarterly Census of Employment and Wages Jack Galvin described the cooperative structure underlying the QCEW program of the Bureau of Labor Statistics (BLS), which produces quar- terly data on employment and wages at the national and subnational (state,

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THE FEDERAL-STATE COOPERATIVE RELATIONSHIP 43 metropolitan statistical area, and county) levels.1 BLS’s federal-state coop- erative efforts date back to at least 1916 and were particularly strengthened by a provision of the Wagner-Peyser Act of 1933 that directed the Labor Department to reimburse states for the operation of statistical systems that contribute to national statistical series. One of five formal federal-state cooperative programs currently main- tained by BLS, the QCEW federal-state partnership is a relatively recent de- velopment at BLS, which assumed technical responsibility for the program from the Department of Labor’s Employment and Training Administration in 1972 and financial responsibility in 1984. QCEW data are known for their comprehensiveness and for their ability to describe local-area economic conditions. Within BLS, QCEW data are also essential as a building block for other statistical programs (e.g., as a benchmark for the annual payroll survey and a sampling frame for establishment surveys), and they are also an important input to the national accounts studies of the Bureau of Economic Analysis. Through the QCEW program, BLS directly funds its state partners to col- lect and edit data from the state-based employment insurance programs. As with vital statistics, the underlying data of the QCEW are, essentially, admin- istrative records: the quarterly contribution reports that employers supply to the state-based employment insurance programs when they pay their taxes each quarter. The approximately 7.7 million quarterly forms, from over 9 million separate business establishments, are estimated to include coverage of about 98 percent of jobs in the United States. In compiling the data, the states are responsible for providing some information that is not directly coded on the quarterly tax forms, such as the industrial classification of the business and verification of physical location address (rather than general mailing address). To provide these supplemental data, QCEW funding re- quires the states to contact each business establishment every 3 years. In addition to funding, BLS’s role is also to provide technical and methodological direction to the data collection. It provides the informa- tion technology systems for the collection and processing of the data and promulgates standards for the data that are sent to BLS. Significantly, BLS plays no role in the structure or format of the quarterly contribution forms, and so the individual state employment insurance programs can vary in the form and filing requirements placed on employers (e.g., whether reports can be filed electronically or on paper). Responsibility for dealing with the va- riety of inputs from employers remains with the states; what BLS’s QCEW funding promotes is a set format for the specific economic elements that are coded in the data files that are returned to BLS. 1 Additional detail on the QCEW program can be found at http://www.bls.gov/cew/ (April 2009).

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44 VITAL STATISTICS Galvin indicated that BLS spending on the QCEW program in 2008 was $49.5 million; the share of that total that is allocated to the states ($30.6 mil- lion) makes it the largest of BLS’s federal-state cooperative programs. From 2000 to 2008, funding for the QCEW grew at an average of 2.9 percent per year, in line with the approximate 2–3 percent increase in the number of businesses in existence each year (and a corresponding increase in workload for the state officials). Galvin noted that BLS has typically been success- ful in securing such “mandatory” increases from the Office of Management and Budget and from congressional appropriators, giving QCEW relatively stable funding.2 As NCHS does with the state vital records offices, BLS negotiates in- dividual QCEW contracts—cooperative agreements—with each state. The QCEW agreements are updated and agreed to on an annual basis. Through these annual agreements, BLS is able to specify (and modify, as appropriate) the expected quality standards for the data, the requirements for protection of confidentiality, and policies for allowable costs. By agreement with the states, BLS’s funding to the states is calculated by multiplying a state’s av- erage government employee annual wage—itself a figure derived from pub- lished QCEW data—by 1.5 by the number of staff positions to be filled in the state. Each state is allocated a base of two positions for supervision (and continuity of operations), and additional positions are calculated on the ba- sis of the state’s workload in the program: for instance, its number of single and multiunit businesses and new business units. Galvin indicated that BLS has concluded that its structuring of the QCEW program—and the stability of funding for it—has improved the quality of the data and improved the consistency of data quality across the states. The annual cooperative agreements provide a means to promul- gate methodological standards, including routines for addressing situations found through review of edit failures in data processing and for the han- dling of missing quarterly tax reports (through imputation). BLS’s provision of information technology to the partners also provides consistency and re- liability in processing: Each state uses one of two technical systems (those used and developed in Utah or Maine), a considerable simplification from 50 heterogeneous technical systems. Galvin noted that the common tech- nical platforms produced a significant benefit in terms of timeliness of data release: over the course of a couple of years, BLS was able to shift its quar- 2 As noted in the discussion of Galvin’s presentation, the use of “mandatory” means in- creases in funding because of increases in the cost of collection (e.g., cost-of-living adjustments to staff salaries), not that the increases are required by law. Galvin noted that BLS does not always receive these “mandatory” increases; in 2007, failure to get $2 million to cover the in- creased costs led BLS to cover the funding by other means, eliminating production of estimates from the payroll survey for several metropolitan areas and cutting sample size from another federal-state cooperative program that collects occupational employment statistics.

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THE FEDERAL-STATE COOPERATIVE RELATIONSHIP 45 terly publication of QCEW data earlier by 3 weeks. By doing so, BLS was responsive to a major client for QCEW data—the Bureau of Economic Anal- ysis, which (with data available that much earlier) can now use the quarterly data to update its personal income estimates four times per year rather than waiting to perform an annual revision. Galvin noted that federal-state cooperation in the QCEW program does occasionally encounter vulnerabilities due to variation in state laws and reg- ulations. State-level changes to filing practices for employers’ quarterly con- tribution reports—the source data for QCEW—can create complications. In one instance Galvin cited, a state requirement that all employers begin filing the forms electronically (rather than on paper) proved difficult for small em- ployers, contributing to glitches in processing and, for the QCEW increased , levels of nonresponse for that state. State confidentiality laws can also com- plicate the use of QCEW information for other purposes: For instance, they may prohibit BLS from sharing the administrative data collected in QCEW to assist the Census Bureau in filling in missing industry codes in its business and employment data. In recent years, the QCEW Program has been further structured in re- sponse to the Workplace Investment Act of 1998. Section 309 of the act (P 105-220) amended the original Wagner-Peyser Act to create specific .L. provisions related to employment statistics. State governors were directed to designate a single state agency as the manager and coordinator of em- ployment statistics for each state, but the act also established more direct oversight responsibilities for these state partners. The Secretary of Labor (and BLS) was directed by the act to develop a process by which 10 direc- tors of these state-designated regions—one for each region—are elected to hold formal consultations with BLS on the cooperative management of the system.3 This was a departure from established procedure in BLS’s federal- state cooperative efforts such as QCEW which had previously been handled , more through BLS’s regional offices than its national headquarters staff. In addition, the 1998 act directed that BLS hold formal consultations with the states at least once each quarter on the products and function of the employ- ment statistics system.4 Galvin noted that the organizational changes needed to comply with the 1998 act were difficult for BLS, given the entrenched practices, but that, by improving communication and feedback, they have improved the program and made it easier to accomplish further change in specific federal-state efforts. 3 BLShas settled on a policy by which these elections are held every 2 years. 4 Specifically, the mechanism used by the act to require these collaborations is the require- ment that the Secretary of Labor develop an annual plan for the national employment statistics program; the consultation with the states is intended to be a key input to the annual plan.

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46 VITAL STATISTICS Box 3-1 Surveys Comprising the Common Core of Data Public Elementary/Secondary School Universe Survey • institutional characteristics, numbers of teachers, enrollment by grade, students participating in selected education programs, dropouts, and high school com- pleters Local Education Agency (School District) Universe Survey • institutional characteristics, number of education staff, and number of students participating in selected education programs Local Education Agency (School District) Universe Survey: Dropout and Completion Survey • number of dropouts from each of grades 7 through 12, and the numbers of high school diploma recipients and other high school completers State Nonfiscal Public Elementary/Secondary Education Survey • state-level counts of students, teachers, other staff, and high school completers National Public Education Financial Survey • state-level collection of revenues and expenditures SOURCE: Adapted from workshop presentation by White and descriptive material at the CCD website (http://nces.ed.gov/ccd/index.asp [April 2009]). 3–C.2 The Common Core of Data Andrew White (National Center for Education Statistics, NCES) de- scribed the CCD, the U.S. Department of Education’s primary database on public elementary and secondary education in the United States. Adminis- tered by NCES, the program annually collects fiscal and nonfiscal data about all public schools (approximately 96,000), public school districts (approxi- mately 18,000), and the 50 states, the District of Columbia, Department of Defense Schools, and those in outlying areas. The CCD comprises five surveys sent from NCES to state education agencies (typically a state department of education) and completed mostly by using administrative data already maintained by the agency; the surveys are listed in Box 3-1. White noted that completing some data items requires the agency to contact local school districts, who in turn may contact indi- vidual schools. The state agency then compiles the data from all levels into prescribed formats and transmits them to NCES. The data gathered from the surveys fall into three categories: 1. general descriptive information on schools and school districts, includ- ing name, address, phone number, and type of locale; 2. data on students and staff, including selected demographic character- istics; and 3. fiscal data that include revenue and current expenditures.

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THE FEDERAL-STATE COOPERATIVE RELATIONSHIP 47 White said NCES began entering into cooperative partnerships in 1985 in an attempt to improve CCD data. Of note was a contract with the Council of Chief State School Officers (CCSSO) to examine the completeness and comparability of data reported to the CCD, as well as to discuss ways to expanded its content and establish common definitions. The Hawkins-Stafford Elementary and Secondary Education Improve- ment Amendments of 1988 (P 100-297) authorized NCES to establish .L. a formal federal-state cooperative system. The goal of this system was to “produce and maintain, with the cooperation of the States, comparable and uniform educational information and data that are useful for policymaking at the Federal, State, and local level” (Hoffman, 2004:x). To implement and support the new cooperative system, NCES, with as- sistance from CCSSO, formed the National Forum on Education Statistics (NFES) in 1989 with a mission (Hoffman, 2004:xii): To develop and propose, cooperatively, a national education data agenda and model(s) for a national data system that will meet the needs of education policy makers and program planners in the decade and be- yond; To inform Federal, State, and local decision makers on the goals and progress of this cooperative education statistics system; To pro- vide an arena in which Federal, State, and local education interests can identify, debate, mediate, and where appropriate, recommend action on education policy, issues, emerging needs, and technological innovation salient to the improvement of education data comparability, uniformity, timeliness, and accuracy at the national level. The NFES also adopted the role of “provid[ing] direction for research and evaluation” and “bring[ing] to the attention of relevant parties such mat- ters as may contribute to the accomplishment of this mission” (Hoffman, 2004:xii). Chief state school officers, federal program heads, and direc- tors of professional associations with an interest in education statistics were asked to appoint liaisons who would represent their various institutions. The NFES formalized its goals, objectives, functions, organizational struc- ture, and operations in January 1990 with the adoption of a Policies and Procedures Manual. In 1996, the NFES expanded its membership by adding one local education agency representative from each state, to be appointed by the chief state school officer. To achieve its mission, the NFES holds regular meetings, including stand- ing committees that address specific issues, and produces a number of re- ports, including a series of “best practice” guides on a wide range of data- related topics. NCES funds state participation in NFES activities and pub- lishes and disseminates definitions and guides from NFES. In 2003, the department launched the Education Data Exchange Net- work Submission System (EDEN) to provide a common system by which state education agencies could transmit their administrative data. Data are

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48 VITAL STATISTICS transmitted by the states to meet the data requirements of annual and final grant reporting, specific program mandates, and the Government Perfor- mance and Results Act. In addition, the EDEN Survey Tool was established to allow transmission of additional data, such as the Civil Rights Data Col- lection and the Indian Education Formula Grant Program Application for Funds. In 2006, the Department of Education launched a more overarching sys- tem called EDFacts which is a central portal for performance and account- ability data reporting, including nonfiscal CCD data.5 White noted that implementation of EDFacts has “done a little damage” to the October 1 reporting deadline. In particular, states that had highly developed data sys- tems in place prior to EDFacts have had a difficult time converting to the new format and its definitions. The department has provided some funding to states to help them enter the EDEN/EDFacts system. Since January 2007, reporting of these data using EDFacts is mandatory (with a 2-year transition period). The establishment of the Statewide Longitudinal Data System Grant Pro- gram has also provided an opportunity for states to apply for grants from between $500,000 and $6 million to develop and implement longitudinal data systems. The grants provide funding for 3-year cycles. Participation has grown substantially every year since the program’s inception in 2005. Many states have been awarded their second 3-year grant, and only eight states have not participated. 5 For more information on EDEN and EDFacts, see http://www.ed.gov/about/inits/ed/ edfacts/overview.html (April 2009).