OMB disapproves this request for approval under the Paperwork Reduction Act. See ED's response of 10/13/98 and OMB memo to file of 10/20/98. The rationale for this action is provided below: 1) OMB notes that the overall study is broken down into three parts - (i) Phase 1 involving 11 sites nominated by Adult ED state coordinators; (ii) Part 1 of Phase 2 involving a case study of 5 sites (this is the part of the study for which ED now seeks clearance); (iii) Part 2 of Phase 2 which would involve a similar case study as Part 1 with an expanded number of sites. OMB further notes that Phase 1 was implemented without an OMB approval in violation of the Paperwork Reduction Act. This violation should be reported in ED's FY 99 Information Collection Budget submission. 2) The methodology of this study is flawed in that only programs implementing instruction methods that ED has deemed as potentially effective are in the sample of sites to be analyzed. ED's ability to gauge the effectiveness (and substantiate that effectiveness) of reading instruction practices in adult ed programs will be limited by a lack of exposure to a wider array of practices. First, the selection parameters have the effect of dictating/restricting the practices and outcomes that are analyzed. Second, while ED may be able to link a limited set of practices with positive learner outcomes, ED will have no way of knowing whether these outcomes are substantively different for those adult participants that are not exposed to these types of practices, nor whether the practices caused the positive outcomes. 3) The methodology of this study is flawed in that the 3) The methodology of this study is flawed in that the sample size is too small. Within each site ED will be seeking information from approximately 2 instructors and 15 adult ed participants. The total sample size for the study would be approximately 8 teachers and 80 adult ed participants. This sample size is not adequate provide enough variation of data among in the different programs as well as variation within d individual programs. Thus, the study will not yield valid analyzable results. 4) Because of the methodological flaws listed above, the study lacks practical utility. ED states in their vely 10/13/98 response: *The study is intended to purposively select program that we have reason to believe are effective so that we can substantiate the effectiveness and then determine the causes of these effect initially in a limited number of sites (Part 1 of the Strategy Evaluation Study), and then potentially in additional sites (Part 2 of the Strategy Evaluation Study.)* Thus, the purpose of the study for which ED seeks clearance would be to gauge the feasibility of repeating the study with an expanded number of sites at some future time. First, ED has not demonstrated that Part 1 of the study (limited sites) is integral to a successful implementation of Part 2 of the study (expanded sites). Second, if a feasibility study is integral, ED has not demonstrated that Part 2 of the study, as designed, would yield results which would allow ED to validly identify practices that adult education instructors could use in order to yield positive learner outcomes for participating adults. Third, ED has not demonstrated that the benefits of conducting such a feasibility study are justified by the costs - - approximately $600,000 - $700,000.
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The U.S. Department of Education has been working with State directors of adult education and local providers to document the learning gains of adult education participants. Because little is known about the effectiveness of adult basic education (ABE) programs for first-level learners, this is an exploratory study. Hence, we are developing measures to describe the operational and instructional characteristics of ABE programs and are testing methods of measuring outcomes. The programs participating in the study were selected based on information collected in previous case studies that had....
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Evaluation of Effective Adult Basic Education Programs and Practices