noted in the data provided by the states, the ACS estimates were shown to fluctuate between years, causing concern among the states about the unpredictability and unevenness of program funding.

In this context, the DoEd commissioned the National Research Council’s Committee on National Statistics and Board on Testing and Assessment to convene this panel to address the accuracy of the estimates from the two data sources and the factors that influence the estimates and to consider means of increasing the accuracy of the data sources or alternative data sources that could be used for allocation purposes.


The panel developed a set of criteria for evaluating which of the allowable data sources the department should use for allocating federal Title III funds: conceptual fit, level of geographic fit, timeliness, quality, cost, fairness, stability, insensitivity to policy and methodological differences, transparency, and comparability.

  • Conceptual Fit. A data element used in an allocation formula should meet the conceptual objectives of the program for which the allocation is aimed. In the case of allocating Title III education funds to states, a data element with a good conceptual fit is one that meets the definition provided in the legislation—the number of LEP and immigrant children and youth in a state. In a larger sense, however, considering the overall objective of the allocation of federal funds, a conceptually fitting data element would provide subnational governments a level of federal funding that is proportional to their need and circumstances. The ACS defines need as the numbers of children and youth who are eligible on the basis of their skill in speaking the English language. The state-provided counts are more conceptually fit in that they define need as those identified by schools through questionnaires and assessments, which are increasingly standardized.

  • Level of Geographic Detail. The state is the key level of detail for which the data should be available. Both the ACS and state-provided estimates are available for both states and local education agencies (LEAs).

  • Timeliness. The elapsed time between the reference period for the estimates and the period for which the allocations are being made should be as short as possible. Both the ACS and the state-provided estimates are available approximately 9 months following the reference period.

  • Quality. The ACS data meet statistical reliability standards and are of acceptable precision. The state-provided counts of English language learners, based on administrative data, are not subject to sampling error, but there may be some different interpretation of the instructions for data collection. The state-provided counts of immigrant children and youth rely on LEA judgments and fall short of the quality of ACS estimates.

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