Complaint Summary

Date Findings Report Sent:

November 24, 2025

Case Number:

25-0569

Grade Level:

Elementary

Person filing complaint:

Parent

School District:

Coventry Public Schools

Allegation(s):

• The Parent alleged that she submitted a written request (34 CFR § 300.613 ) via email to the District, seeking the Student’s education records including, “any raw data collected (ABA, speech, OT, behavioral logs, Gen Ed) for [the Student’s] record”. The Parent alleged that the District initially produced monthly engagement graphs and summary charts (e.g., “average monthly engagement” and “average assent withdrawal”), but refused to provide daily raw data on the grounds that such materials are not education records. Finally, the Parent alleged that the District did not provide copies of police reports filed by the District as part of the requested education records.

Conclusion(s):

• Raw data that are directly related to a student, maintained by an LEA, are related to specific clinical, educational or other services provided to a student, or that record the staff member’s direct observations or evaluations of student behavior, including the student’s success in attaining specified objectives are considered education records and are not considered sole possession records. Raw data are not required to be maintained by the District, but such raw data specifically related to a student are considered education records during the time that the record creator chooses to maintain such data. As such, only during the time that such data are being maintained, are they subject to the provisions of records requests. The raw data collected for the progress monitoring of the IEP by the Student’s BCBA, Speech and Language Pathologist, and Occupational Therapist was considered to be part of the Student’s education record during the time that such data was maintained by those practitioners prior to the time that such data was disposed of. When the records request was made, the BCBA, the SLP, and the OT had each implemented a practice of recording the raw data, entering it into a larger data record, then disposing of that raw data, so no such data existed to be provided to the Parent. Therefore, it is concluded that the District was not out of compliance with 34 CFR § 300.613 for this portion of the allegation. No corrective actions will follow. With regard to the lack of provision of the police reports to the parent, police reports are not considered education records, therefore the school was not obligated to provide them as part of the education records request. It is concluded that, for the portion of the allegations related to the police reports, the District was not out of compliance with 34 CFR § 300.613. No corrective actions will follow.

Corrective Action(s):

• No required corrective actions