A version of the following public comment was submitted to the Iowa Department of Education and Thomas Mayes on November 3, 2026.
Thank you for the opportunity to submit public comment on proposed rulemaking regarding Chapter 17, “Open Enrollment and Other Enrollment Options,” Iowa Administrative Code.
Open enrollment laws can benefit students and districts. They ensure students can attend public schools that are the right fit. Many students use these programs to transfer to A- or B-rated school districts, escape bullying, access college-level courses or smaller class sizes, or shorten their family commutes. Additionally, four of five rigorous studies on open enrollment’s effect on participants’ academic achievement found either a significant positive effect or no effect.
A report from the nonpartisan California Legislative Analyst’s Office and a 2023 Reason Foundation study both found that open enrollment’s competitive effects also encourage public school districts to improve.
Research also shows that K–12 open enrollment is widely used and supported. Reason Foundation’s research published in Harvard University’s Education Next found 1.8 million students in 27 states and Washington, D.C., used this policy. Notably, more than 41,000 of Iowa students in traditional public schools, or 9% of them during the 2024-25 school year, used open enrollment to attend schools that are the right fit for them.
However, identifying open enrollment’s effects on families, taxpayers, and districts requires detailed open enrollment data. Improving Iowa’s rules can help.
To date, at least six states–Arkansas, Kansas, Nebraska, Oklahoma, West Virginia, and Wisconsin–collect district-level data about why transfer applicants were denied (masking data to protect students’ identities). Wisconsin’s report, published annually, is the most comprehensive of these and provides an ideal model for Iowa.
For each rejected applicant, districts must identify the reason for the denial per the categories set by the Wisconsin Department of Public Instruction. This ensures uniform application of criteria, improves transparency, and helps explain how districts implement their policies.
At a minimum, Iowa districts should report rejected transfer applications as denied for one of the following reasons: insufficient regular education space, insufficient special education space, a student’s recent disciplinary record (such as an expulsion or multiple out-of-school suspensions), or other. The “other” category should be limited to specific criteria, such as late or incomplete applications or an applicant not being age-eligible for the school.
While school districts can identify multiple reasons for each denial, they should enumerate each category separately. This way, the Iowa Department of Education can identify the most common reasons for rejection by district and across the state. Moreover, the agency should publish these data annually (masking when necessary) on its website, as four other states do. Ideally, this report should include all district-level open enrollment data, including the number of transfers, rejected and approved applicants, and why they were denied.
This data matters because it can show policymakers and the public the barriers students face in the public school system. For example, data from Nebraska and Wisconsin indicate that students with disabilities are rejected at higher rates than their peers without disabilities.
Without data like this, state policymakers would be in the dark about how open enrollment programs are implemented. Better open enrollment data gives policymakers the tools they need to make informed, data-driven decisions. Overall, this is an excellent opportunity to improve open enrollment data and build a stronger public education system for Iowa’s families.