FR 2020-29152

The document under discussion is a notice from the Department of Education (ED), as part of their regulatory activities related to the Family Educational Rights and Privacy Act (FERPA). Issued on January 5, 2021, this notice seeks public comments on a proposed extension of existing information collection requirements, which are being maintained without any changes. This process complies with the Paperwork Reduction Act of 1995, designed to minimize the public's reporting burden while ensuring necessary data collection.

General Overview

FERPA is a federal law that ensures the privacy of student education records. This notice announces the Department's intent to continue collecting specific information from educational institutions and agencies, necessitating their feedback by February 4, 2021. The goal is to gather comments on various aspects of the information collection, such as its necessity, accuracy, and potential to impose excessive burdens.

Significant Issues or Concerns

One notable concern is the lack of transparency in how the burden of 1,914,593 hours is calculated for these informational activities. This substantial number raises questions about its accuracy and underlines the importance of clarity in communicating estimates to the public.

Additionally, a staggering 20,293,021 estimated annual responses might seem overwhelmingly high, leaving some stakeholders unsure about individual reporting obligations. Clarity is crucial to alleviate any perceived imposition on respondents.

The language used, such as "extension without change," might be somewhat opaque for the general public. People unfamiliar with bureaucratic processes might benefit from clearer explanations about what these terms entail and how they specifically impact them.

Moreover, directions for submitting comments involve somewhat convoluted website navigation, potentially discouraging public participation. A more straightforward process or improved guidance could enhance involvement.

Finally, while the document calls for public feedback on several topics, it falls short of indicating how this feedback will influence future actions or the timeline for such actions. Stakeholders might feel their contributions could be disregarded without assurance.

Broader Public Impact

For the general public, this notice represents an ongoing commitment by the Department of Education to balance regulatory needs with minimizing administrative burdens on educational institutions and other stakeholders. Engaging stakeholders in feedback can result in improved clarity and usefulness of collected information.

Impact on Specific Stakeholders

Educational Institutions and Agencies: Directly impacted by these requirements, they must navigate the complexities of compliance without incurring unnecessary costs or effort. The outcome could affect their operational efficiency if the burdens are not managed well.

Parents and Students: The document indirectly impacts parents and students as FERPA regulations aim to protect their privacy rights. Any changes or continuations in information collection efforts hold the potential to affect how their data is recorded and disclosed.

In conclusion, while the process reflects a routine regulatory task, stakeholders' active participation is crucial to align the Department's practices with practical realities, potentially enhancing the quality and relevance of the data collected. Efforts to simplify engagement and improve clarity will serve to empower stakeholders effectively.