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Interscholastic Athletic Opportunities Disclosure – Frequently Asked Questions

This page was revised July 2018.


 Why is the Pennsylvania Department of Education (PDE) requiring this information? 

Act 82 of 2012 added Article XVI-C to the Public School Code of 1949 (24 P.S. § 16-1601- C), requiring PDE to collect this information.

Why is the report only for grades 7 through 12? 

The law specifies the reporting grade levels of secondary students.

Are marching bands, clubs and intramurals included? 

No, the law only requires the collection of information directly related to interscholastic athletics.

Why does this report not include band or clubs? 

The law only requires the collection of information directly related to interscholastic athletics.

Who must complete the disclosure form? 

The law applies to all public school entities that offer interscholastic athletic opportunities to its students in grades 7 through 12.

If my school does not fund any athletic teams, must I complete the disclosure form? 

No, the law only requires schools offering athletic opportunities to complete the form. School entities that do not fund athletics teams are not required to report. If your school has students participating in interscholastic athletics funded at another public school entity, that entity should include the students in its count on its form.

Duties of PDE

 What is PDE's role in implementing Act 82 of 2012 (24 P.S. § 16-1601-C)? 

PDE's roles include: developing the disclosure form to collect data from school entities; posting forms on the department's website; and submitting an annual report concerning information contained in the completed disclosure forms to the General Assembly by January 15 of each year.

Historical Data Collection

How far back in a school's history do we have to go to provide the historical data for each team? 

If your data has not changed from the previous year, just carry over the data from last year. This information will not be pre-populated. PDE advises local education agencies (LEA) to use whatever resources are reasonably available to accurately supply the information required. By way of example, some LEAs may find old yearbooks, news clippings, or other documents found at the LEA helpful in completing this section.

Filing of Disclosure Forms

Who must file the Interscholastic Athletic Opportunities Disclosure Form?  

All public school entities that have students in grades 7 through 12 must file the disclosure form. Those LEAs that do not fund athletic teams will only complete page 1 – General Information.


How should a school entity report co-ed or grade-level teams? 

The school entity should choose the appropriate team to report the participants and continue each year with that same grade level team. For example, if a school entity reports the golf team as male, it can add the female numbers in the box provided. If you place co-ed teams under one gender continue through the years to come.

What is the source of the student totals on the left side of the spreadsheet for gender and race/ethnicity? 

LEAs should use enrollment data which would be reported in the PIMS system.


How should a school entity report an athlete who competes for both a varsity and junior varsity team? 

An athlete should be counted once on the team that they play on for the majority of the games.

How do I count a student athlete that competes in more than one athletic program on the race and gender table? 

For students that participate in more than one sport or athletic program, you count the student as a participant in each program. For example, a student that plays baseball and football, should be counted twice in overall race or ethnicity and gender total counts.

If the school sponsors one junior high basketball and football team that includes 7th and 8th graders, where do we classify them? 

The school entity should choose which team best describes the athletes and continue to document them in this manner moving forward.

Is Competitive Cheer the same as Supportive Cheer? 

No, you will not include any supportive cheer teams that cheer at other sport games. Competitive Cheer has an interscholastic athletic schedule and competitions.


What constitutes a full-time coach? 

In Pennsylvania there are no full-time coaches in high school programs; they are only employed at the college level. All high school coaches are part-time.

Do the activities of volunteer coaches need to be reported? 


Do the salaries and benefits for coaches need to be reported? 

Yes, this should be documented under compensation.

Do we have to report a coach's time if he/she only coaches a club sport team? 

No, only when they coach interscholastic athletic teams that compete.

Athletic Trainers/Athletic Director

Does the cost for our athletic director need to be reported? 

No, you will not include the cost or expenses for athletic directors.

If an athletic director also serves as an athletic trainer, should their time be reported separately when they are doing training work? 

Their time should be documented, and expenses included only when they are performing athletic trainer responsibilities.

If we do not have an athletic trainer but hire a school nurse for emergencies, do we count this expense? 

When the school nurse acts as an athletic trainer, only their time spent as an athletic trainer would be documented as the expense for the team.

How do we account for the time an athletic trainer spends with each team when they are outside for multiple practices or events? 

They will need to account for their time as a percentage to describe how much of their time was spent with each team.

Does a contracted athletic trainer need to be reported? 

All expenses for the in-house athletic trainers, as well as the out-sourced athletic trainers from an agency must be included in the disclosure form.


What is the collection time-frame? 

You should begin collecting data from July 1 – June 30.

Do activity fees or pay-to-play fees need to be reported? 

No, because this would be considered revenues, which is not reported.

How do you report costs for a team from multiple school buildings, like middle and high school buildings?  

Each school building should complete the General Information section (page 1) of the Interscholastic Athletic Opportunities Disclosure Form. The school building where the sports team practices and plays should complete the rest of the Interscholastic Athletic Opportunities Disclosure Form. The school building where the team does not practice, and play will not have to complete the form. Their athletes should be accounted for by the school where the students go to practice.

For Additional Information

For additional information and documents on Interscholastic Athletic Opportunities Disclosure, please visit PDE's website at:

If you have specific questions, please send them to: