Subject: File Number S7-2024-05
From: Kirk Weber
Affiliation:

Oct. 17, 2024

Dear Federal Agency Rulemaking,

I am a Colorado school district consultant and therefore not tied to a specific entity.  However, as a previous employee for the Colorado Department of Education, I was actively involved in the electronic financial data collection imposed by NCES on all public schools.  NCES requires the use of a standardized chart of accounts, the individual school district data (fund accounting) is submitted to the State Department of Education annually, in which such data is subject to numerous edits to ensure that the data is checked and verified against the standardized chart of accounts.  The information submitted to NCES is further analyzed and reviewed for outliers before it is accepted.   It does not appear that this proposal knowledges the active involvement of NCES, the State Departments, nor the individual districts in establishing and maintaining a viable financial data collection process.  Nor does it recognize that such entities are already engaged in such electronic financial reporting of data.

Sincerely,

Kirk Weber