Skip to main content

Proposed Changes to the School-Level Finance Survey

All4Ed submitted joint comments to the U.S. Department of Education with the Education Trust, Education Reform Now, and National Center for Learning Disabilities to improve and strengthen its proposal for collecting school-level finance data from states. Read or download our comment below.

Stephanie Valentine, PRA Coordinator
Strategic Collections and Clearance, Governance and Strategy Division
U.S. Department of Education LBJ, Room 6W203
400 Maryland Ave. SW Washington, DC 20202–8240

Re: Agency Information Collection Activities; Comment Request; Common Core of Data (CCD) School- Level Finance Survey (SLFS) 2022-2024 (Docket No. ED-2022-SCC-0120)

Dear Coordinator Valentine,

The undersigned civil rights, education, and immigration organizations are pleased to submit comments in response to the U.S. Department of Education’s (USED) proposed changes to the School-Level Finance Survey (SLFS). We submit these recommendations as a collaboration of national organizations seeking to advance shared education equity priorities through federal, state, and local policy and advocacy.

If implemented well, the SLFS could provide centralized and accessible school–by-school expenditure data, which is central to USED’s mission and responsibility to protect equitable access to education for students across the nation. Our organizations also believe that the SLFS represents an important opportunity for key stakeholders—including parents, researchers, and members of the advocacy community—to better understand resource equity in, and across, schools and districts to better address inequity.

Research shows that school funding positively influences student achievement, but that too often, school funding systems shortchange districts serving high concentrations of students of color and students from low-income families. School-to-school funding disparities, meanwhile, have been more challenging to document, but are also coming to light as a result of improved reporting of school-level spending data, including new mandatory data reporting requirements for all states in the Every Student Succeeds Act (ESSA).

The importance of — and attention on — school-level spending data will only increase, especially as the research and advocacy communities turn attention to understanding where and how effectively federal COVID relief funding was spent to support students’ recovery. So, we are pleased to see that USED is taking steps to replace the school-level spending data that was removed from the Civil Rights Data Collection (CRDC), while building on the work that states have already done to report school-level spending data aligned with the ESSA requirement.

Any expansion of the SLFS must be accompanied by an improvement in the National Center for Education Statistics’ (NCES’) ability to publicly report the data in a timely manner. At the same time, we believe it is important for USED to ensure that states remain committed to reporting high-quality and timely school-level spending data on their report cards, as required by ESSA. We recognize that reporting complete and accurate school-level spending data required in ESSA has been a difficult task for states. However, since the Edunomics Lab’s National Education Resource Database on Schools (NERD$) includes FY19 data from 49 states and the District of Columbia, it appears that states are rising to the challenge. To ensure that the ESSA data do not get “left behind” while making a transition to a national, and more comprehensive, data collection through SLFS, we recommend that USED continue to provide technical assistance to state educational agencies to improve their ability to report school-level spending data that aligns with SLFS definitions and meets the ESSA requirement.

Over the last few years, the school-level spending data “ecosystem” — which includes data from the CRDC, the ESSA per-pupil expenditure reporting requirement, and the SLFS — has seen many changes. This includes a new reporting requirement because of ESSA, removal of the data from the CRDC, and a substantial revision of definitions in the SLFS to align with the ESSA reporting requirement. As such, we appreciate that NCES has outlined an incremental action plan to phase-in these additional changes to the SLFS. However, we recommend the following changes to the implementation timeline.

Whether or not NCES makes the substantive changes above to the incremental action plan that is described in the federal register notice, we offer the following conforming recommendations to improve the clarity of the requirement, quality of the data to be collected, and transparency about the data already collected.

Thank you again for the opportunity to provide feedback on these proposed changes to the SLFS, and for your commitment to improving the field’s understanding of how much money states and districts spend on schools.


Education Reform Now
The Education Trust
National Center for Learning Disabilities