NWEA is a nonprofit organization providing assessment, professional development, and research services to SEAs and LEAs. As a user of PII on behalf of LEAs and SEAs, we find the proposed changes in FERPA to be very positive. We are specifically supportive of changes permitting redisclosure and contracting rights to organizations not under the direct control of the educational authority.

NWEA currently must create a burden for itself and LEAs, when conducting research using statewide data, because we must secure separate authority from each participating LEA in the study. We believe the proposed §99.31(a)(6)(ii) permitting a state or local educational authority or agency to enter into agreements with research organizations for statutorily-specified purposes, and to redisclose data held in the SLDS, will reduce the data burden and the compliance effort associated with the studies with no loss of protection of the PII being redisclosed.

Further, NWEA is pleased with the opening of pipelines between PK-12 education, higher education, and workforce data providers. We believe this will bring dramatically greater value to the data at each level through integration in a longitudinal fashion.  NWEA has not yet conducted research across these levels, but sees significant benefit from endeavors that will become possible as a result of this change.

Finally, NWEA applauds the Department’s general efforts in recent years to reduce the burden on education providers, researchers, and other data users to access and use these data for the benefit of our nation’s children.  We recognize and fully support the intent of FERPA to protect sensitive information about our citizens, but believe the law’s intent is not to create roadblocks for the legitimate and responsible use of the data to improve educational services and increase student learning. The Department is taking significant and positive steps to support the statutory intent while decreasing the burden of compliance.