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ERC approves DACA study with FERPA amendment and removes state wage data from request
Summary
The advisory board approved a proposal to study DACA's effects on juvenile crime and school discipline, but directed the researchers to revise the FERPA purpose statement and to remove Texas Workforce Commission wage-request fields that were judged unusable for the study.
The ERC advisory board approved a proposal to study the consequences of Deferred Action for Childhood Arrivals (DACA) policies on juvenile crime and school disciplinary outcomes, while requiring two substantive changes to the application.
"My project is titled the impact of DACA on juvenile crime and school safety," said Barbara Lundenberg, a PhD candidate in economics at Tulane University, who presented the study. The researchers proposed using the ERC's immigrant flags as a proxy for likely DACA-eligible youth and a difference-in-differences research design to estimate whether DACA eligibility altered juvenile crime and school disciplinary behavior (suspensions and expulsions).
During discussion, board members emphasized that the ERC proxy does not reveal actual immigration status and asked the team to be explicit in any final reporting about the proxy's limits. Legal and board members also questioned whether the project fit FERPA audit/evaluation exemptions because DACA is not a federally funded education program; the board asked the research team to revise the FERPA purpose language to clearly justify a studies exemption ("improve instruction") or other appropriate ground.
Board members also recommended removing Texas Workforce Commission (TWC) wage file elements from the request after staff noted those TWC fields rely on Social Security numbers and would not be useful to identify DACA-eligible youth. The board voted to approve the project provided the researcher (1) updates the FERPA purpose language to state the applicable studies exemption (improve instruction) and (2) removes the TWC wage elements from the data request.
The motion to approve carried unanimously after the researcher agreed to the amendments. The board flagged the importance of the analytic caveat that the immigrant flag is an imperfect proxy for DACA receipt and must be presented as such in analysis and publications.
