Pursuant to the Maryland Public Information Act (MPIA), I am requesting access to and copies of aggregate, non-identifiable data regarding students enrolled in the Intensive Resource Classroom (IRC) model/program within the Howard County Public School System (HCPSS) over the past seven (7) school years (from SY 2018–2019 through SY 2024–2025).
Specifically, I am requesting the following data, disaggregated at the aggregate level to protect student privacy and ensure compliance with FERPA:
1. Age ranges of students enrolled in the IRC model each year (e.g., 5–7, 8–10, 11–13, 14–16, 17–21).
2. Race/ethnicity categories of students enrolled (consistent with HCPSS/State reporting categories).
3. Gender of students enrolled.
4. Residential zoning of students enrolled (reported by feeder pattern, cluster, or region not by individual addresses).
5. Primary disability/diagnosis categories (consistent with IDEA/COMAR reporting categories, e.g., Autism, Intellectual Disability, Emotional Disability, etc.).
I am requesting this information by school year for the specified seven-year period. To ensure student privacy, I understand that HCPSS may need to suppress or redact small cell sizes (e.g., counts below 10) in compliance with FERPA.
Responsive to this request, Special Education staff indicate HCPSS operates only two Intensive Resource Classrooms with one at the middle school level and one at the high school level. The following reflects counts of students participating per year. Please note, the middle school program began in SY18-19 and the high school program began in SY21-22:
MS Year Number by School Year
2018-19 <10
2019-20 <10
2020-21 12
2021-22 11
2022-23 11
2023-24 14
2024-25 12
2025-26 11
HS Year Number by School Year
2021-22 <10
2022-23 10
2023-24 13
2024-25 18
2025-26 15
HCPSS must protect against the potential disclosures of personally identifiable information about students as required by both the Family Educational Rights and Privacy Act of 1974 (FERPA), which restricts access to student records, and MPIA GP § 4-313, which prevents disclosure of school district records pertaining to individual students. In accordance, HCPSS follows the Maryland State Department of Education and the National Center for Education Statistics’ guidelines for protecting student privacy in public reporting and suppresses the following from responsive records: populations that fall below 10; percentages that are less than or equal to 5, or greater than or equal to 95; categories directly related to specific student records; and/or information that can reasonably identify an individual student or reveals information from an individual student’s record or could do so when combined with other publicly accessible data.
Given the small populations in each program, each of the counts for the specific data points you have requested regarding the students falls below 10 or would be able to be calculated when combined with the total counts above. Therefore, we are unable to release additional data regarding the students within these programs.
On October 15, 2025, we received your follow-up request seeking this data “represented through ranges (e.g., 5–9 students), percent bands (e.g., <10%) or combined groupings.” While this approach may align with student data privacy methods under FERPA, under the MPIA process, and as advised in the Nineteenth Edition of the Maryland Public Information Act Manual created by Maryland’s Office of the Attorney General, an agency is only obligated to produce existing records and is not required to generate new data or summarize data.