Texas Even Start Administrative Manual Statement Regarding PEIMS Data

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Texas Even Start Administrative Manual

June 2004, (Revised January 2008)

Statement Regarding PEMIS Data

Even Start Question about Accessing Data from School Systems

A partner in an Even Start project that is a community based organization (CBO) can access data from a school district for children participating in Even Start, for the purpose of providing information to the State educational agency (SEA) for monitoring and evaluation under the State’s Even Start performance indicators. The State Even Start office will submit the information to the Public Education Information Management System (PEIMS). Family Educational Rights and Privacy Act (FREPA) legal staff for the United States Department of Education (USDOE) advises the following:

The Even Start project, including the CBO partner, is considered an “educational agency or institution” under the FERPA regulations (34 C.F.R. sections 99.1 and 99.3). As such, the FERPA law and regulations apply equally to school districts and CBO partners in an Even Start project (essentially, they would be considered as a single entity), and it does not make any difference which entity is the fiscal agent.
Authorized representatives of State and local education authorities may have access to education records in connection with an audit or evaluation of Federal or State education programs, or for the enforcement of or compliance with Federal legal requirements which relate to those programs (34 C.F.R. section 99.35), so long as those representatives meet certain requirements. Those requirements are:

The information that is collected must be protected in a manner that does not permit personal identification of individuals
The information that is collected must be destroyed when no longer needed for the purposes indicated above.

These two restrictions do not apply if the parent or eligible student has given written consent for the disclosure.

Therefore, the State Even Start office, as an authorized representative of the State educational agency (SEA), could obtain personally identifiable information about children in school from local Even Start programs (which have school districts as partners) to use for the purpose of monitoring and evaluation. However, if the SEA wishes to redisclose that information, such as putting it in a State data base like PEIMS, it would have to remove any personally identifiable information about the students unless it obtained written consent from the parent or student for the redisclosure. For additional information or technical assistance, you may call (202) 260-3887 (voice). Individuals who use the TDD may call the Federal Information Relay Service at 1-800-877-8339. Or you may contact us at the following address: Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue, SW Washington, D.C. 20202-4605.

FOR INFORMATION ONLY

May 28, 2003

TO THE ADMINISTRATOR ADDRESSED:

SUBJECT: PEIMS and Even Start Family Literacy Programs Data Exchange

In order to meet new Federal reporting requirements for accountability on Even Start programs (LIFT Act Title XVI of Division B of H.R. 5666) the Texas Education Agency (TEA) is requesting your assistance to ensure the accuracy and quality of data that will be submitted to the U.S. Department of Education. Federal regulations require the implementation of Indicators of Program Quality to measure Even Start program performance (Sec.1210 [20 U.S. 6369a]).

Federal definition of family literacy: Services that are of sufficient intensity in terms of hours, and of sufficient duration, to make sustainable changes in a family, and that integrate all of the following activities: (1) interactive literacy activities between parents and children; (2) training for parents regarding how to be the primary teacher for their children and full partners in the education of their children; (3) parent literacy training that leads to economic self-sufficiency; (4) an age-appropriate education to prepare children for success in school and life experiences.

The purpose of this request is to identify parents and children participating in Even Start Family Literacy Programs through the matching of local school district data submitted to TEA against Even Start program data. A coordinated effort at the local level between Even Start Coordinators and PEIMS Coordinators will help ensure that these children are identified, thus ensuring that available services are provided according to Federal regulations.

Even Start programs may include Community Based Organizations (CBO) as a partner. The CBO is considered an “educational agency or institution” under the Family Educational Rights Privacy Act regulations (FERPA) (34 C.F.R. Sections 99.1 and 99.3). As such, the FERPA law and regulations apply equally to the school district and the CBO partners (if applicable to your district). It does not make any difference which entity is the fiscal agent.

Authorized representatives of Federal and State Even Start programs may audit local Even Start programs for program evaluation and compliance with Federal legal requirements, which relate to these programs (34 C.F.R. Section 99.35). In fulfilling this request, TEA is asking that the Even Start Coordinator ensure the following data is entered into TESPIRS on a quarterly basis. The Even Start coordinator is required to:

identify and document all Even Start program participants whether they are attending public schools or adult education programs according to the appropriate category (PEIMS or TEAMS), and;
work with the district PEIMS Coordinator to verify the student data with the data on file in the PEIMS Coordinator’s office.

In order to be in compliance with (Sec.1240 [20 U.S.6369a]) it is the Agency’s intent that this data match will enable TEA to assess your program’s progress based on PEIMS data and TAAS/TAKS or other state alternative assessment scores for the Even Start participants in your district. Future program funding will be contingent upon sufficient program performance based upon the evaluation of program quality indicators developed by TEA.

Effective Fiscal Year 2003-2004, there will be an Even Start Indicator in PEIMS for Even Start early childhood children, school age children and teen parents participating in local Even Start programs.

Your district’s assistance in completing and submitting data into TESPIRS is greatly appreciated. If you have any questions concerning this request please contact the Texas LEARNS Even Start Manager at (713) 696-0700.

Sincerely,

Robert Muller, Ph.D.
Chief of Staff
Initiatives and Administration

Cc: PEIMS Coordinator
Even Start Coordinator

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