COBRA comments and Department responses

Feedback in response to
The Department of Education (ED) Notice: Agency Information Collection Activities; Comment
Request; Annual Performance Report for the Gaining Early Awareness for Undergraduate Programs

CoBro Consulting provides evaluation services in completion of the U.S. ED Annual Performance Report
for up to 30 GEAR UP grants each year. The following feedback is the collective, official feedback from
the CoBro Consulting corporate principals.
1. Comments: Page 5, in the table, re: the row heading: “Results: Has the objective been met?
(Yes/No)”It is not clear what the response should be if the objective was met for one cohort but
not another, or if the objective was met compared to targets from the grant proposal or
compared to a more current/applicable comparison group. We suggest adding ‘Partially’ as a
potential answer (so Yes/No/Partially) and a request for further explanation in the table.
Comments: Commenter requested that the objective table which asked the question if the
objective has been met; should not just have a Yes or No answer but instead; the commenter
suggest adding the word partially.
Response: The Department concurs with this comment and agrees to make this change.
Change: The Department will add partial as a possible response to the question.
2. Comments: Page 13, Ethnicity and/or Race Unknown Table. The total for Ethnicity and total for
Race should be separate and not added together, since those who are Hispanic or Latino will
also be one of the listed races. Given this, we suggest adding a row for Non-Hispanic Latino and
a row for ‘total’ to the ethnicity section, to make it clear that they are not combined with race.
Response: The demographic data collection section is consistent with the Department of
Education’s policies which require the program to collect ethnicity and race in this manner.
Change: None
3. Comments: Page 14, last sentence: If you choose to do so, please complete the following table
indicating the unduplicated number of GEAR UP students who have been identified as
homeless (as defined by the McKinney-Vento Homeless Assistance Act) or are in foster care
(as defined by Title IV of the Social Security Act). Suggest changing the underlined ‘are’ to ‘have
been’ or ‘were’ in foster care, since the instructions are to report on the previous year and to be
consistent with the subsequent table.
Response: The Department concurs with this comment and agrees to make this change.
Change: The Department will change are to were.

February 18, 2016

3.1 Comments: Page 16, table: Participant Distribution by Grade and Status (Cohort Students)
Using the definitions below the table, students in both columns (d) and (e) would be included in
either column (b) or column (c) as well (since before they withdrew or dropped out, they would
have been new or continuing at some point during the reporting period), so the total as
currently stated in (g), # of Total GEAR UP Students Participants, would double-count some
students. We suggest changing the formulas to the following to match the definitions below the
table:
(f) # of Active GEAR UP Students = (b)+(c) – (d) – (e)
(g) # of Total GEAR UP Students = (b)+(c)
Response: The Department agrees with the commenter on changing the formulas.
Change: The Department will change the formulas for columns (f) and (g).
3.2 Comments: Re: the table heading: (g) # of Total GEAR UP Students Participants: Since ‘# of
active participants’ is examined in a different section, it is confusing to specify ‘Participants’
here. Suggest removing the word ‘Participants’.
Response: The Department agrees with the commenter.
Change: The Department will remove the word “Participants”.
4. Comments: Page 17 table: Participant Distribution by Grade and Status (Priority Students)
Comments: Please see suggested changes in #4 above. These same changes to the equations
apply to this table.
Response: The Department agrees with the commenter on changing the formulas.
Change: The Department will change the formulas for columns (f) and (g).
5.

Comments: Page 19, Active Participation in GEAR UP Activities, #3 states: “What is total,
unduplicated number of parents, guardians, or other family members that actively
participated in one or more GEAR UP activities during the reporting period?” In this section,
the number of parents/guardians/family members is asked. In a later section (#6 on page 20),
the number of students with a participating family member is asked. Tracking the number of
individual family members increases the burden substantially, and is virtually impossible to
accurately track each individual parent/guardian/family member participating, for logistical
reasons. We suggest maintaining consistency with the later table and asking ‘total unduplicated
number of students with a parent, guardian, or other family member that actively
participated…’
Response: The Department agrees with commenter.

February 18, 2016

Change: The Department will change the question to read “What is the total unduplicated
number of students with a parent, guardian, or other family member that actively participated
in one or more GEAR UP activities during the reporting period?
6. Comments: Page 20, instructions above table: Core Activities Provided to Parents, Guardians,
and Family Members. The last sentence of the instructions reads: “For each type of activity
provided, indicate (a) the unduplicated number of students whose parents, guardians, or family
members participated in the activity during the reporting period; and (b) the sum total of hours
that the sum total of hours that parents, guardians, and family members participated in the
activity.” Suggest removing the duplicate phrase (‘the sum total of hours that’).
Response: The Department agrees with commenter.
Change: The Department has removed the duplicate phrase “the sum total of hours that”.
7. Comments: Page 23, Course Enrollment table. First column header: Grade student was in
when course was enrolled. Suggest changing to ‘Grade student was in when course was taken’.
Response: The Department agrees with commenter.
Change: The Department will change enrolled to taken.
8. Page 25, instructions above table Educational Progress by Current GEAR UP Students
8.1 The beginning of this section (Section VI) at the top of page 23 instructs to report on students in
the prior complete school year. Therefore, I this table title Educational Progress by Current GEAR
UP Students, the word ‘current’ should be deleted here, and the following edits should be
applied as well.
Response: The Department agrees with the commenter.
Change: The Department will delete the word “current” from the heading.
8.2 Comments: Re: this portion of instructions: “Enter the numbers in the row that coincides with
the grade the students are in during the prior school year (e.g., If you served sixth grade during
the first year of the grant and a standardized test was administered the first year to that sixth
grade, please report on results of that standardized test when submitting the APR in the second
year placing the information in the row for 7th grade since those students would be seventh
graders in the second year.)” Example should say ‘placing the information in the row for the
grade level the students were in during the reporting period (i.e., 6th grade in this example)’
Response: The Department believes the current instructions are explicit and do not need to be
revised.
Change: None
9. Comments: Page 25, table: Educational Progress by Current GEAR UP Students. The first
column heading in the table says “Current Students.” Given the instructions at the beginning of

February 18, 2016

this section to report on the prior year information, we suggest changing this heading to “Grade
During Reporting Period.”
Response: The first column actually says “Current Grade” not Current Students and the
instructions for this section are very explicit.
Change: None
10.2 Comments: The column heading of: “Number of Students with 5 or More Unexcused Absences
During the First 2 Quarters of the School Year.” Also given the instructions to complete the table for
the entire prior school year, we suggest changing this to “..During the Entire Prior School Year.”
Response: The Department agrees with the commenter
Change: The Department will change the heading of the column to “During the Entire Prior School
Year.
10. Comments: Page 26, last row of table: Baseline High School Graduation and College Enrollment
Data. The example Fulton H.S. school year is 2008-20069. We suggest removing the extra digit
from the year.
Response: The Department agrees with the commenter.
Change: The Department has updated this table to reflect recent years.

February 18, 2016