Comment on FR Doc # 2013-11821

We write to seek clearer policy regarding how Race to the Top will consider and meet the needs of lead-poisoned children: children who have had a blood level equal to or greater than five micrograms per deciliter (µg/dL). Past and emerging research results tell us more and more about the learning challenges facing lead-poisoned children. We attach our briefing paper on this subject. The Advisory Committee on Childhood Lead Poisoning Prevention of the Centers for Disease Control and Prevention is working on a statement on the educational needs of lead-poisoned children. http://www.cdc.gov/nceh/lead/ACCLPP/educationWG.htm Lead poisoning is not considered in and of itself a disability but lead exposure causes changes to children’s brains that require highly effective early childhood educational services. Eligibility for IDEA and special education services encompasses developmental delays, of which lead poisoning is one per the IDEA regulation. However, states may decide whether to use a developmental delay designation, how to define it, and to what age ranges it should apply. In some states, lead-poisoned children might be found to have developmental delays consistent with the state’s definition. Children with lead exposures may be classified as having “another health impairment,” a disability category listed in IDEA. The IDEA statute explicitly includes lead poisoning as a covered impairment. Alternatively, they might be found to have a “Specific Learning Disability,” which is another IDEA disability category. In both cases, they would also have to meet the second criterion of needing special education as a result of the health condition. Considering that there are more than 500,000 lead-poisoned children, we believe that Race to the Top would best meet its important and ambitious goals by drawing greater attention to this population’s needs as follows: [please refer to the attachment]