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To the U.S. Department of Education's National Center for Education Statistics

Comments on State of Preschool Survey 2013-2015

February 12, 2013 |

On February 12, 2013, the Early Education Initiative submitted comments in response to a request from the National Center for Education Statistics at the U.S. Department of Education on the State of Preschool Survey 2013-2015. The State of Preschool Survey, conducted annually by the National Institute for Early Education Research, is a critical source of data and information for families, researchers and policymakers.

The full text of the comments is available below and in the “related files” column to the right. They were also submitted to the National Center for Education Statistics through regulations.gov.


National Center for Education Statistics
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

February 12, 2013

Dear Sir or Madam,

Thank you for the opportunity to comment on the proposal for NCES to conduct the annual State of Preschool Survey for 2013-15. We commend NCES on this proposal. As an organization that focuses on improving early education and that has built a public resource based on data from the preschool survey, the New America Foundation sees this survey as critical to building a better understanding of education opportunities for our country’s young children.

We would like to provide remarks on two of the five questions posed in the call for comments: Is this collection necessary to the proper functions of the Department? And how might the Department enhance the quality, utility, and clarity of the information to be collected?

Is this collection necessary to the proper functions of the Department?

The U.S. Department of Education, with leadership from Secretary Arne Duncan, has demonstrated a commitment to early learning in recent years by creating the first-ever Office of Early Learning within the Department and spearheading federal early education initiatives like the Race to the Top-Early Learning Challenge. In Duncan’s own words, “[w]e have to get out of the catch-up business, and the best way to get out of the catch-up business and to level the playing field is to get our babies off to a great start...increase access to early childhood education – making sure it is high-quality and reaching children and communities historically underserved.”

And yet, so far, little information is available through the federal government on how many children are enrolled in preschool, aside from Head Start. Fortunately, over the years, many states have invested in state-funded pre-K programs and are already collecting this data or are in a better position to do so than in past years. The National Institute for Early Education Research (NIEER) created the State of Preschool Survey to collect that data, and for nine years NIEER has been publishing results through its State of Preschool Yearbooks, providing a reliable annual study of the funding and quality of such programs across the country. One reason for our confidence in NIEER’s survey is that it collects information on state-funded pre-K programs in both school districts and community-based organizations. If NCES contracts with NIEER to continue administering this survey (an approach that we think makes sense), that comprehensiveness should be continued. Too often in the past, data on pre-K that are presented to the U.S. Department of Education only include school-based pre-K programs, providing an incomplete picture of how many children are served by publicly funded pre-K programs.

In short, we strongly support NCES’s proposal to bring the State of Preschool Survey into its body of work on education data collection. Early education data shine a light on the disparities of access and quality that children face in their first years of development. Without standardized collection of pre-K data across the country, journalists, policymakers, and parents would lack important context about children’s access to pre-K programs and how these programs are funded in comparison to K-12 education. These data are necessary to ensure better pre-K – and PreK-12 -- policymaking within Congress, throughout the Department of Education and throughout the Administration as a whole. The State of Preschool Survey will help provide essential data to answer these questions and measure progress in achieving the objectives over time.

Recommendations on enhancing the quality, utility, and clarity of the information to be collected

1.       Begin collecting data on enrollment and funding at the local level

Currently, states struggle to provide good early education data at the school district level. We believe that a national task force or meeting of experts could help NCES change this. States need guidance on how to gather and report on enrollment in state-funded pre-K programs within the boundaries of their school districts. At the moment, this is very difficult to do because data from community-based organizations are not designed to mesh with data from school districts. Without a full picture of how many children are enrolled in publicly funded pre-K in their districts and what programs they attended, superintendents, principals, and early grade teachers lack valuable information about the students they are teaching.

2.       Collect child, program and workforce level data

The Early Childhood Data Collaborative, another leader in the field of early education data, has proposed and advocated for the use of its 10 Fundamentals of Coordinated State Early Care and Education Data Systems. The New America Foundation believes those Fundamentals promote a deeper understanding of early learning systems and would recommend that several be incorporated into the State of Preschool Survey.

In particular, New America recommends that states, taking appropriate measures to guard child privacy, collect child-level demographic data and participation in early childhood programs; data on early education program sites and quality; and information on the early learning workforce by program. Additionally, the New America Foundation believes that the ability to link child-level data systems with K-12 and other systems is critical, and would propose that the survey collect information from states on current links between their pre-K data and their K-12 longitudinal data systems.

3.       Make distinctions about dosage

For pre-kindergarten programs, dosage – the number of hours or days that a program is open to children – may act as a critical indicator of students’ school readiness. Per-child funding cannot be calculated without an understanding of whether the data apply to a morning and afternoon class each day or to a full-day program. The data cannot be comparable across districts and states until dosage is included as a component of the collection process.

4.       Include publicly funded early education opportunities for infants and toddlers

The New America Foundation recognizes that gaps in learning between students of different socioeconomic and demographic groups begin well before pre-kindergarten. Thus, collecting data on the enrollment of infants and toddlers in publicly funded early learning and home visiting programs, as well as the funding available for such programs, at the state and local levels are critical metrics for policymakers. Additionally, information on state policies for early education before pre-K provides essential information for researchers on the availability of those programs for needy families.

5.       Open the survey to questions about kindergarten

On a related note, although K-12 funding is typically understood to mean that funding per student within a district is roughly equivalent for each grade, in reality, kindergarten funding may vary greatly. In some states or school districts, kindergarten is funded separately from first through twelfth grade. Additionally, dosage issues mean that kindergarten per-pupil funding may refer to either full-day or half-day programs, and therefore may not be directly comparable within and between school districts and states. Adding kindergarten data, including dosage, to the annual data collection process would help to unmask some of these serious disparities in funding and access to full-day kindergarten.

6.       Incorporate the data into the Common Core of Data

Ensure that pre-K data can be downloadable within the National Center for Education Statistics’ Common Core of Data. Enabling pre-K data to be part of the Common Core of Data would place early learning on a platform level with elementary and secondary education and offer data linked to other federal data on demographics, enrollment, spending and outcomes. However, we would also urge NCES to ensure the data collected remain comparable to prior NIEER data collections. NIEER is the only reliable, comparable source of pre-kindergarten data available across all fifty states. To lose its capacity as a data stream spanning nearly a decade would be an unfortunate loss for the early education community.

The New America Foundation thanks you for the opportunity to offer comments on the State of Preschool Survey 2013-2015. The preschool survey must continue – and collections of early childhood data need to expand in the coming years – to inform policymaking and spur the improvement of early education opportunities for all children. 


Lisa Guernsey
Director, Early Education Initiative, New America Foundation


* About New America Foundation’s use of the State of Preschool Survey

Thorough, consistent data collection is essential to measuring the effectiveness and quality of early learning programs, and to promoting those practices. The New America Foundation’s Early Education Initiative relies on NIEER’s annual State of Preschool survey data to display many of the data points in its public Federal Education Budget Project (FEBP) database. FEBP is a centralized source of demographic, funding and outcomes data for every state, school district, and institution of higher education in the country. The New America Foundation’s Early Education Initiative last year embarked on a project to collect and publish in FEBP data from all 50 states and Washington, D.C., on state-funded pre-kindergarten, Head Start programs, and early intervention services provided under IDEA Section 619. The data were collected at the state and school district levels. (To explore this database, see edbudgetproject.org)

However, the data proved challenging for states to provide, and the collection could not have been completed without the publication of the NIEER annual State of Preschool Yearbooks and the expertise of NIEER staff. The information NIEER provides to the public is authoritative and impeccably researched. Without it, we would be grasping in the dark to understand the variations in pre-K programs across state lines.

Furthermore, the very act of data collection through a standardized format encourages states to standardize the way they collect data and think about their early learning programs. This can help states to consider the full continuum of education, from birth through postsecondary education. It will also allow states to build a continuous educational infrastructure, including child and teacher assessments and data systems, that is more meaningful and reliable.

In short, we strongly support NCES’s proposal to bring the State of Preschool Survey into its body of work on education data collection.