Our Work
Comment on IDEA “Significant Disproportionality” Reporting Requirements
The OCR Alumni Collective filed objections to the U.S. Department of Education’s proposal to eliminate state reporting of “Significant Disproportionality” under the IDEA.Eliminating the reporting requirement does not eliminate states’ obligation to track significant disproportionality and address it; this eliminating no burden to states. Instead, it simply makes it more difficult for others — including the federal government, states, school districts, educators, and parents — to identify and address the problem.
The OCR Alumni Collective filed objections to the U.S. Department of Education’s proposal to eliminate state reporting of “Significant Disproportionality” under the IDEA. Eliminating the reporting requirement does not eliminate states’ obligation to track significant disproportionality and address it; this eliminating no burden to states. Instead, it simply makes it more difficult for others — including the federal government, states, school districts, educators, and parents — to identify and address the problem.
Comment on the Civil Rights Data Collection (CRDC)
The OCR Alumni Collective filed objections to changes to the CRDC, including to the end of data collection about gender identity. It also provided information about the necessity of conducting an accurate and valid data collection and sharing the information in a timely manner.
The OCR Alumni Collective filed objections to changes to the CRDC, including to the end of data collection about gender identity. It also provided information about the necessity of conducting an accurate and valid data collection and sharing the information in a timely manner.
Comment on the Department of Energy’s Direct Final Rules
The OCR Alumni Collective filed objections to the Department of Energy’s (DOE’s) direct final rules which impermissibly and unlawfully attempted to alter longstanding regulations implementing Title VI, Title IX, and Section 504. Specifically, the Collective objected to: (1) DOE’s attempt to no longer hold recipients of federal funding accountable when their actions have the effect of excluding individuals based on their race, color, national origin, or sex; (2) DOE’s attempted recission of legally necessary provisions to protect persons with limited English proficiency; (3) DOE’s attacks on sports which would limit, not enhance, opportunities for girls and women; and (4) DOE’s attempts to upend access to buildings for persons with disabilities by rescinding access standards applicable to new construction and alterations.
The OCR Alumni Collective filed objections to the Department of Energy’s (DOE’s) direct final rules which impermissibly and unlawfully attempted to alter longstanding regulations implementing Title VI, Title IX, and Section 504. Specifically, the Collective objected to: (1) DOE’s attempt to no longer hold recipients of federal funding accountable when their actions have the effect of excluding individuals based on their race, color, national origin, or sex; (2) DOE’s attempted recission of legally necessary provisions to protect persons with limited English proficiency; (3) DOE’s attacks on sports which would limit, not enhance, opportunities for girls and women; and (4) DOE’s attempts to upend access to buildings for persons with disabilities by rescinding access standards applicable to new construction and alterations.