• Cost. Both ACS estimates and state-provided counts are available at minimal extra cost.

  • Fairness. The U.S. Census Bureau, which administers the ACS, ensures the data are free from manipulation. State-provided counts have improved such that data are similarly free from manipulation; however, states’ discretion over various policies may affect perceptions of fairness.

  • Stability. The state-provided counts are relatively stable from year to year. The 1-year ACS estimates for smaller states are subject to noticeable variation. The 3-year ACS estimates are more stable than the 1-year estimates and than the state counts.

  • Insensitivity to Policies and Methodological Differences. The ACS estimates are not sensitive to administrative practices or policy differences, but they may be sensitive to differences in the demographic composition of respondents. The state-provided counts are somewhat sensitive to state decisions regarding identification, testing, and program entry and exit policies.

  • Transparency. The ACS data are collected by professional staff using highly standardized, well-documented methods. The state-provided counts are collected by varying methods and depend on LEA implementation so that documentation is not readily available.

  • Comparability. The ACS data are comparable across geographic and demographic dimensions. The state-provided counts conform to basic federal definitions but are not comparable in their constructs due to differences in state tests and the states’ classification and reclassification criteria.

In sum, the panel concludes that the ACS data are slightly better on some characteristics, while the state-provided data have advantages on others, which is not reflected in the current formula.


Data Sources for Title III Allocation Formula

RECOMMENDATION 1 As soon as technically possible, the U.S. Department of Education should begin to incorporate state-provided counts of English language learner students into Title III formula allocation calculations. Initially, the state-provided data should be given a weight of 25 percent of the allocation, with the remaining 75 percent weight given to the American Community Survey data.

RECOMMENDATION 2 In the portion of the allocation that is based on state-provided data, the U.S. Department of Education should use the state-provided count of the number of students who are determined not

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