• Schools were instructed to only enter zeroes for data that was tracked and for which no cases were reported. But, as reports from the U.S Government Accountability Office office have described, some school officials have expressed confusion in recent years about reporting requirements, and some districts have submitted inaccurate entries, inputting zeroes when data is actually missing or not tracked.
• If districts did not have data to submit, they were supposed to, instead of entering zeroes, leave entries blank and then provide further explanation for missing data.
• When districts are unable to provide required data – including because they do not collect data due to policies that prohibit restraint and seclusion of students – they’re required to develop and submit an action plan that explains what data cannot be provided, why, and to outline how they plan to collect and report the data accurately in the future.
• When districts are unable to provide required data, of if data they submit triggers an error, and they are unable to provide an action plan, this triggers a force certification. The submission is certified on behalf of the district provided it “has unique circumstances that prevent them from certifying.” Such districts do not expect to be able to provide data in subsequent data collections. (In 2017-18, “there were a large number of force certifications in post-collection” due to efforts to ensure districts correctly reported zeroes. “Data force certified for this reason during the post-collection work were not required by OCR to have an action plan.”)
• NYC special note: For the 2017-18 data, an action plan was issued for New York City Public Schools “due to a large amount of missing data,” including restraint and seclusion data. The electronic action plan “timed out” before the submission could populate the missing data due to the district’s size. “Therefore, the district submitted a paper action plan and was force certified.”
• Data was missing for some schools because the district did not certify their submission before the data collection period closed.
• For some schools, districts did not submit any data because they indicated it was not applicable for those schools.
• Some of the federal data released by the U.S. Department of Education was "suppressed" due to concerns about "poor quality" including data that appeared potentially "flawed" or otherwise "problematic."
• In other cases, data submissions from districts were flagged by the department for possible data quality issues that were not resolved.
• As a privacy measure "in order to prevent the disclosure of identifying information," the department made small, random adjustments to the data, however zeroes were not altered.