NASDSE recognizes and agrees with the overall concern related to disproportionality in special education. These concerns were behind the Department of Education's release of a regulation in December 2016 that laid out steps states were to take to identify and address this issue. NASDSE has learned that the Department of Education is postponing implementation of this regulation. States are moving forward to implement the regulation as it is currently written and NASDSE does not believe that implementation should be postponed from the current timeline contained in the regulation. At the same time, a number of states have questions/concerns regarding how the regulation addresses the calculation of disproportionality that we would like to see OSEP address. We hope that OSEP will work with NASDSE and the state directors of special education to address their concerns related to how disproportionality is calculated and identified so that true disproportionality can be addressed in meaningful ways.