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to verify the accuracy of the data they collect and report. One commenter recommended that this section be amended to be consistent with section 618(b)(2) of the Act, which provides that the Secretary may permit States to obtain the data required under section 618 of the Act through sampling, to avoid a duplication of effort in States that sample to obtain section 618 data. Several commenters

suggested that complying with the requirements in §303.724

would place a significant burden on States and their data

collection contractors. One commenter stated that some States use electronic systems to collect and track Part C data and that these systems do not necessarily rely on EIS providers to submit child counts to the lead agency, and thus, an EIS provider could not be expected to certify child count data. The commenter recommended that EIS provider certification only be required when applicable to

a State’s procedures for reporting unduplicated and

accurate child counts.

Discussion: Collection of accurate, unduplicated data begins at the EIS provider level. Therefore, requiring the lead agency to establish procedures that must be implemented by EIS providers, including certifications about the accuracy of the data and the dates by which EIS providers must report that data to the lead agency, is