All4Ed Comments on Proposed Revision to Perkins V Consolidated Annual Report

June 09, 2025

RE: Comments on Proposed Revision to Perkins V Consolidated Annual Report (CAR) Information Collection Request Docket No. ED-2025-SCC-0014, OMB #1830-0569

We at All4Ed are writing to express our strong concerns regarding the Department of Education’s proposal to revert the Perkins V Consolidated Annual Report (CAR) to its previously approved version. While we understand the Department’s interest in reducing administrative burden, we believe this rollback would eliminate critical improvements to Career and Technical Education (CTE) data collection and reporting that are essential for promoting equity and accountability in CTE, and this would undermine the ability of the CTE field to best serve our nation’s students through learning what works, and documenting and sharing successes across states.

The Proposed Rollback Would Eliminate Essential Transparency and Accountability Measures:

The Department’s proposal to eliminate recently established requirements represents a significant step backward for CTE performance measurement and equity. Specifically, reverting to the previous version would remove:

Critical Definitional Requirements: The elimination of required definitions for key terms such as “size,” “scope,” “quality,” “high-skill,” “high-demand,” and “meaningful progress” would return us to a system where states define these essential concepts inconsistently, making cross-state comparisons impossible and undermining public accountability. Without these definitions, policymakers and the public cannot accurately assess whether Perkins V-funded activities are truly meeting their intended goals.

Essential Performance Data Specifications: Removing the numerator and denominator specification requirements would eliminate much-needed transparency in how states calculate core performance indicators. This clarity was crucial for ensuring that graduation rate calculations align with the Every Student Succeeds Act (ESSA) definitions and that performance data is comparable and reliable across states. Without these specifications, we return to a system where performance data lacks the precision necessary for meaningful accountability.

Enhanced Data Disaggregation: The rollback would eliminate improved data collection on postsecondary outcomes disaggregated by program type and employment placement data that helps identify equity gaps. This represents a lost opportunity to understand how different student special populations—particularly students of color, students from low-income backgrounds, and students with disabilities—experience varying outcomes in CTE programs.

Industry-Recognized Credential Tracking: Reverting would eliminate the focus on identifying and tracking industry-recognized certificates and certifications, which is essential for ensuring CTE programs provide meaningful, marketable credentials that employers value. This loss would undermine efforts to align CTE with labor market needs and demonstrate the value of the program.

Middle-Grade CTE Data: The previous version lacks data collection on middle-grade participation in Perkins V-funded activities, eliminating our ability to identify early interventions that promote equitable access to high-quality CTE pathways.

Why Administrative Burden Cannot Justify This Rollback

While we understand concerns about reporting burden, the improvements that would be eliminated represent essential accountability measures that directly serve student equity and program quality. The estimated 12,636 annual burden hours across 54 respondents averages approximately 234 hours per respondent annually—a modest investment given the critical importance of accurate, comparable CTE performance data.

Moreover, these reporting requirements were designed to address fundamental problems in CTE data collection that have persisted for years:

• Wide variability in how states define and measure core elements of Perkins V
• Lack of comparability in performance data across states
• Insufficient data to identify and address equity gaps
• Limited understanding of CTE’s long-term impact on student outcomes

Alternative Approaches to Address Administrative Burden

Rather than eliminating these essential requirements, we strongly urge the Department to consider alternative approaches:

Enhanced Technical Assistance: Provide robust, equity-focused technical assistance to help states effectively implement these requirements, particularly for states serving large populations of students from low-income backgrounds and students of color.

Phased Implementation: Consider a phased approach that prioritizes the most critical requirements while allowing for additional time to implement more complex elements fully.

Technology Solutions: Invest in technological solutions and data systems that can reduce the manual burden of these reporting requirements while maintaining their accountability benefits.

Streamlined Processes: Collaborate with states to identify specific aspects of the narrative requirements that can be streamlined without compromising essential accountability information.

Undermining the American Dream for Our Most Vulnerable Students

The proposed rollback is particularly troubling because it undermines the promise of career and technical education as a pathway to the American Dream for students who have historically been excluded from economic opportunity. The enhanced data collection requirements were designed to identify and address persistent disparities in CTE access and outcomes that prevent many students from accessing the middle- class careers that CTE programs are intended to provide.

For example, significant gender gaps persist in CTE participation, with women comprising only 16.7% of Architecture and Construction concentrators and men only 23.1% of Health Science concentrators. These disparities don’t just represent statistical imbalances; they represent barriers to economic mobility and career opportunity that limit students’ ability to achieve economic security and prosperity.

Students of color, students with disabilities, English learners, and students from low-income backgrounds deserve CTE programs that open doors to family-sustaining careers and economic advancement. These students often depend on CTE as their primary pathway to middle-class jobs and the American Dream of upward mobility. Without enhanced data collection and reporting requirements that shine a light on disparities and hold programs accountable for serving all students effectively, these critical pathways to economic opportunity will remain inequitable and inadequate.

Career and technical education has the potential to be one of our nation’s most powerful tools for expanding access to the American Dream, but only if we maintain the accountability measures necessary to ensure these programs truly serve all students with excellence and equity. Reverting to less rigorous reporting requirements abandons our commitment to ensuring that every student, regardless of background, has access to the high-quality CTE programs that can launch them into rewarding careers and economic security.

Recommendations

We strongly urge the Department to:

1. Withdraw this proposed rollback and instead work with states to address implementation challenges through enhanced support and technical assistance.
2. Maintain the enhanced definitional requirements that provide essential transparency about CTE program quality and outcomes.
3. Preserve performance data specifications that ensure reliable, comparable data across states.
4. Retain disaggregated data collection that enables identification of equity gaps and disparities.
5. Continue industry-recognized credential tracking that demonstrates program value and labor market alignment.
6. Provide additional resources and support to help states implement these requirements effectively rather than eliminating them.

Conclusion

The enhanced reporting requirements that would be eliminated by this proposal represent years of thoughtful work to improve CTE accountability and ensure that career and technical education truly serves as a pathway to the American Dream for all students. While we understand concerns about administrative burden, these requirements serve essential functions that directly impact students’ ability to access family-sustaining careers and economic mobility, particularly for those from historically underserved communities who often depend on CTE as their primary route to middle-class prosperity.

Career and technical education has the potential to be one of our nation’s most powerful engines for expanding economic opportunity and upward mobility. However, this potential can only be realized when we maintain robust accountability measures that ensure programs are delivering on their promise to prepare students for high-skill, high-demand careers that provide economic security and advancement.

We urge the Department to reconsider this rollback and instead focus on supporting states in implementing these critical accountability measures. The students served by Perkins V-funded programs, many of whom are counting on CTE to open doors to rewarding careers and the American Dream, deserve no less than the highest standards of transparency, accountability, and equity in their educational programs.

All4Ed stands ready to work with the Department and states to support effective implementation of enhanced CTE data collection and reporting requirements that ensure career and technical education fulfills its promise as a pathway to economic opportunity and prosperity for all students.