The U.S. Department of Education, through its Office of Special Education and Rehabilitative Services, published a notice in the Federal Register on December 4, 2025, proposing an extension without change of an information collection request under Part B of the Individuals with Disabilities Education Act (IDEA). This action, docketed as ED-2025-SCC-0976, invites public comments until February 2, 2026, as required by the Paperwork Reduction Act of 1995. The collection, OMB Control Number 1820-0600, involves record-keeping and reporting by state and local educational agencies on aspects of special education, such as services for parentally placed private school students and state complaint procedures. While these data are not submitted to the federal government, they support compliance with IDEA's mandates to provide free appropriate public education to children with disabilities. This extension underscores the ongoing need for such administrative processes to ensure accountability in special education, amid broader discussions on regulatory burdens and data utility in federal education policy.
Background on IDEA Part B and the Information Collection
Part B of the Individuals with Disabilities Education Act, enacted in 1975 and reauthorized multiple times, including through the 2004 amendments, requires states and local educational agencies to provide special education and related services to children aged 3 through 21 with disabilities. The law emphasizes individualized education programs, parental involvement, and procedural safeguards. The information collection in question stems from these requirements, mandating that agencies maintain records and, in some cases, report data to other public entities or the public, though not directly to the Secretary of Education.
According to the Federal Register notice, the collection covers specific areas including private school placements, parentally placed private school students with disabilities, state high-cost funds for expensive special education cases, notifications for free and low-cost legal services, early intervening services to prevent over-identification of disabilities, listings of hearing officers and mediators, state complaint procedures, and local educational agency applications under Part B. These elements are outlined in the Act and its implementing regulations at 34 CFR Part 300. The notice states that the extension is 'without change,' meaning no modifications to the scope, methods, or burden estimates are proposed.
The Paperwork Reduction Act (PRA) of 1995 governs this process, requiring federal agencies to obtain Office of Management and Budget (OMB) approval for information collections and to periodically review them to minimize public burden. The Department of Education's proposal aligns with PRA section 3506(c)(2)(A), which mandates public notice and comment opportunities. Historical context shows that this ICR was last approved in a similar extension, reflecting a pattern of routine renewals to sustain IDEA's administrative framework without introducing new requirements.
Key Players and Procedural Details
The primary agency involved is the Office of Special Education and Rehabilitative Services (OSERS) within the Department of Education, led by officials such as Ross Santy, who signed the notice as Chief Data Officer in the Office of Planning, Evaluation and Policy Development. Respondents include state, local, and tribal governments, specifically educational agencies responsible for IDEA implementation. The notice estimates 73,503 annual responses and 353,169 burden hours, figures unchanged from prior approvals.
Public participation is facilitated through the Federal eRulemaking Portal at regulations.gov, with alternatives for mail or email submissions if the portal is unavailable. Comments are solicited on the collection's necessity, accuracy of burden estimates, timeliness of data use, ways to enhance quality and clarity, and methods to reduce respondent burden, including through technology. As noted in the supplementary information, all comments become public records, promoting transparency in the regulatory process.
For further inquiries, the notice directs individuals to Diana Yu at OSERS, reachable at 202-245-6371. This structured approach ensures that stakeholders, including educators, administrators, and advocacy groups, can influence whether the collection continues as is.
Legal and Policy Context
The requirements trace back to key provisions in IDEA, such as section 1412(a)(10) on parentally placed private school children and section 1415 on procedural safeguards, including state complaints and mediation. Regulations at 34 CFR 300.132, for instance, detail reporting on parentally placed students, while 34 CFR 300.600 addresses monitoring and enforcement. These are not new; they build on precedents like the Supreme Court's decision in Board of Education v. Rowley (1982), which defined 'free appropriate public education' under IDEA, emphasizing the role of data in compliance.
Politically, IDEA has enjoyed bipartisan support, with funding and oversight involving congressional committees like the House Education and Workforce Committee and the Senate Health, Education, Labor, and Pensions Committee. However, debates persist on administrative burdens, as highlighted in reports from the Government Accountability Office, which have critiqued federal education data collections for potential overlaps. Advocacy organizations, such as the Council for Exceptional Children, often weigh in on such notices, balancing the need for robust data against resource strains on underfunded agencies.
Different perspectives emerge: proponents argue that these records ensure equitable services and accountability, citing data's role in identifying disparities in special education. Critics, including some state education departments, contend that the burden hours—estimated at over 350,000 annually—divert resources from direct student services, potentially exacerbating inequities in rural or low-income districts. The notice itself acknowledges these tensions by inviting comments on burden minimization.
Implications for Special Education Administration
In the short term, if approved, the extension maintains continuity in how agencies handle IDEA Part B obligations, avoiding disruptions in processes like notifying parents of legal aid or tracking high-cost cases. This stability supports ongoing federal monitoring, as OSERS uses aggregated data for annual reports to Congress under IDEA section 1418.
Longer-term implications involve the evolving landscape of education data policy. With advancements in digital tools, there is potential for streamlined collections, as suggested in the PRA's emphasis on information technology. However, without changes, the ICR may face scrutiny in future reviews amid broader pushes for regulatory relief, such as those seen in executive actions under various administrations aimed at reducing paperwork.
Perspectives vary: federal officials view it as essential for upholding civil rights protections, while local agencies may see it as an unfunded mandate. Parent advocacy groups often support strong record-keeping to enforce rights, whereas fiscal conservatives highlight costs, estimated here at hundreds of thousands of hours across respondents.
The Department of Education's proposal to extend this information collection without change reflects a commitment to sustaining the administrative backbone of special education under IDEA Part B. Key takeaways include the unchanged burden estimates and the open comment period, which could shape future iterations. Moving forward, potential next steps involve OMB review post-comment period, with possible adjustments based on feedback. Ongoing debates may center on integrating technology to reduce burdens or aligning with emerging priorities like inclusive education, while challenges remain in balancing data needs with resource constraints for state and local agencies.
