Technology Based Learning Evaluation Supporting Statement Part A FINAL

Supporting Statement for
Paperwork Reduction Act 1995 Submission:

Evaluation of Technology-Based Learning Grants

The U.S. Department of Labor’s Employment and Training Administration (ETA) is seeking Office of Management and Budget (OMB) approval to collect data from participants of training programs funded by ETA’s Technology-Based Learning (TBL) Initiative on practices and customer satisfaction related to their participation in the program. The primary goal of the data collection is to provide feedback from participants on their experiences with TBL programs funded by ETA. The data ETA seeks to collect will provide a snapshot of: a) pre-participation employment and wages, b) usage of TBL courses and objectives in enrollment, c) outcomes such as completion rates, degree/certificate/credential attainment, and post-participation employment and wages, and d) customer satisfaction with the TBL program. These data will be gathered using a customer survey given to individual participants in TBL programs funded under the grant. This survey will be administered once to each individual.

The importance of this investigation is underscored by recent efforts to promote the use of TBL within the workforce system. In 2006, ETA launched the TBL Initiative to encourage and advance the use of TBL programs within the workforce system, and funded several small TBL projects as demonstrations. When these projects showed promise, ETA decided to provide systematic support for TBL on a national basis. As such, ETA awarded grants to 20 organizations around the country to promote and support models of TBL for training in various high-demand, high-growth industries and occupations for both job-seekers and incumbent workers. Exhibit 1 presents the 20 grantees and their proposed training programs and target groups.

Exhibit 1: TBL Grantees

Organization	Service Area	Industry/Sector	Participants Targeted
Able-Disabled Advocacy, Inc	San Diego County, CA	Information Technology	Incumbent workers; job seekers1
College of Southern Nevada	Las Vegas Metro Area, NV	Health Care	Job seekers
County of Orange/OC Workforce Investment Board	Orange County, CA	Health Care	Incumbent workers
Dillard University	New Orleans, LA Atlanta, GA Savannah, GA Detroit, MI	Green Construction	Incumbent workers; job seekers
Greenville Technical College	Greenville, SC and neighboring counties	Health Care	Incumbent workers; job seekers
Guidance Center	Wayne County, MI	Adult Care	Incumbent workers
Gulf Coast Community College	Florida	Robotics	Incumbent workers
Hillsborough Community College	Florida	Manufacturing	Incumbent workers; job seekers
Illinois Department of Commerce and Economic Opportunity	Chicago Area	Information Technology	Incumbent workers; job seekers
Madisonville Community College	Western Kentucky, contiguous regions of Indiana, Illinois and Tennessee	Health Care	Incumbent workers; job seekers
North Central Texas College	North Texas Southern Oklahoma	Health Care	Incumbent workers; job seekers
Northern Virginia Community College	Northern Virginia	Geographic Information Systems	Job seekers
Ogden-Weber Applied Technology College	Northern Utah	Information Technology	Incumbent workers; job seekers
Reno Community Services Agency	Reno-Sparks Metro Area, NV	Transportation	Job Seekers
Research Foundation of SUNY	New York State	Health Care	Incumbent workers; job seekers
Temple University	Philadelphia, PA	Information Technology	Job Seekers
University of Colorado, Denver	Colorado	Energy	Incumbent workers; job seekers
Wake Technical Community College	North Carolina	Information Technology	Incumbent workers; job seekers
West Virginia University at Parkersburg	West-Central West Virginia	Health Care	Incumbent workers; job seekers
Western Governors University	Nationwide	Health Care	Incumbent workers

Given the innovation of using TBL to provide workforce training, ETA has a particular interest in documenting participant experiences in these grant-funded programs. Thus, this data collection effort is designed to provide useful information to ETA regarding customer satisfaction and outcomes, as well as identify training program features that are positively related to participant outcomes, which can be used to inform the future development and support of TBL training in the workforce system. The key areas that will be addressed by the customer survey are:

1. Why do participants choose to enroll in TBL programs?

2. What other kinds of workforce services or assistance do participants receive?

3. How easy is it to use TBL tools, and what barriers to use do customers encounter?

4. How satisfied are customers with the quality of training they received, and with their overall TBL training experience?

5. What are the educational and employment outcomes of participants?

6. How are participant outcomes related to specific TBL program features?

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The TBL Initiative grants are funded under Section 414(c) of the American Competitiveness and Workforce Improvement Act of 1998 (included as Attachment A), which requires that the Secretary of Labor conduct an evaluation to measure the grants’ effectiveness. Thus, the Evaluation of Technology-Based Learning (TBL) Grants is a two-year evaluation of grantees funded to implement TBL programs that increase worker access to training in a timely and effective manner, while simultaneously stimulating the development of new and innovative models and uses for TBL in the workforce system. The evaluation will document and assess learners’ experiences and outcomes related to participating in such a program, and the implications for the workforce investment system.

As a key part of the TBL evaluation, ETA’s contractor will collect administrative data from grantees and administer a customer survey. The customer survey will provide information on customer satisfaction and participant outcomes, and thus inform future TBL projects. Since grantees are presently reporting only limited data about TBL participants to ETA, reasons for participation, challenges to participation, other workforce services received, and, of particular importance, satisfaction with TBL training and services would not otherwise be available in the absence of the survey.² Thus, in order to more thoroughly evaluate the TBL program, participation, outcomes and satisfaction data will be gathered from both the administrative data and the customer survey. A hardcopy of the survey is included as Attachment B.

The collection of administrative data from grantees will serve a two-fold purpose--provide some basic demographic, programmatic, and outcome information on participants in TBL programs, and supply participants’ contact information for survey administration. Participants’ email address (in conjunction with participant name and, if available, Student ID number) will be used as the matching key to link administrative data and survey responses. The reason for using email addresses in this fashion is two-fold. First, because programs all incorporate TBL and email is a primary source of communication with participants, grantees are likely to keep complete lists of participants’ email addresses. Second, by their nature all (active) email addresses are unique and can be linked easily back to the participant.

ETA’s contractor will work collaboratively with the grantees to assess the quality of data in their management information systems (MIS) and coordinate the extraction and transfer of these data. The data items that will be requested from grantees are listed in Exhibit 2.

Exhibit‑2: Data Items to be Requested from Grantees

Contact Information		Employment Status at Enrollment
●	Participant Name	Training Program Name
●	Address	Outcomes
●	Email Address	●	Training program completion (including date of completion)
●	Phone Number
●	Student ID Number (if applicable)	●	Degree, credential or certificate attainment (including data of award)
Demographic Information
●	Date of Birth	●	Date of exit
●	Gender	●	Entered unsubsidized employment (including date entered)
●	Race/Ethnicity
●	Veteran’s Status	●	Entered training related employment
●	Disability Status	●	Industry sector of employment

However, since the TBL grantees being studied as part of this evaluation are a varied group made up of state or local workforce agencies, community colleges, non-profit organizations, and universities, their data collection practices and administrative data systems also vary. Thus, administrative data may not be consistent across grantees, and it is expected that some grantees might have significant gaps in data. The customer survey will serve to fill these gaps and provide some consistent data about TBL customers, their training programs, and services received. Given the relatively low number of potential participants, a survey of the entire population who exited from the TBL programs during a six-month period is possible.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

This is a new collection. ETA has selected Social Policy Research Associates to conduct the Evaluation of TBL Grants, including collecting administrative data, administering the survey, and conducting the analysis. ETA will use the results to assess the TBL learners’ experiences and outcomes related to participating in such a program and the implications this project has for the workforce system.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

After participants are mailed a pre-notification letter about the customer survey, they will be sent an email with an embedded link to the contractor’s website where there will be an electronic version of the survey. Via this site, participants will be able to complete the survey and submit it directly to the contractor. All survey data received in this fashion will be stored in a secure database, accessible only to authorized contractor staff.

Since respondents for this survey will have accessed the Internet and used online tools as part of their participation in TBL training programs, it is expected that barriers to accessing the online survey will be minimal and this population will be comfortable completing an on-line survey and receiving and transmitting information about the survey via email.

Participants will also be sent reminders through email and mail to participate in the survey, each of which will include a link to the online survey website. Participants that do not respond to the online survey after the first email reminder will be sent hard-copy versions, along with a postage-paid return envelope so that they may have the option of participating in this fashion. The cover letter to the hard-copy survey will detail how customers can access the electronic version of the survey, if that is their preferred mode of participation, by providing the URL link to the online version. Following the mailing of the hard-copy survey, non-responding customers will be sent another email reminder and then a final reminder postcard through the mail. Those who do not complete either the online or mail survey after receipt of these reminders will be telephoned to elicit their responses orally.

Participants who submit the survey electronically will be sent $15 online gift cards via email from the contractor. Those who complete the hard-copy version of the survey will also be able to opt to receive their gift cards electronically, or the contractor will send the gift cards via post.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information being requested is not otherwise available. Since ETA has only recently funded TBL programs, little information is available about the use of TBL programs within the workforce system. In addition, prior research into TBL programs has not focused on the study of customer satisfaction and outcomes as they pertain to non-traditional students, such as job seekers, or occupational training programs in some of the industry sectors represented by grantees, such as manufacturing.

The evaluation will utilize administrative data from grantees, as well as survey data. The administrative data are expected to contain demographic information on participants, program enrollment, and some educational and employment outcomes. However, since administrative data across grantees are likely to be inconsistent or incomplete, administrative records themselves are not sufficient for conducting the evaluation of TBL programs, and therefore the evaluation will rely also on survey data collected from TBL programs’ participants. The proposed survey will provide useful information on these participants’ satisfaction related to such TBL training programs, and their employment-related outcomes.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The collection of information does not impact small businesses or other small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If the information collection is not conducted, the information available about the success of the grantees funded under the TBL Initiative will be extremely limited. Since administrative data from grantee are likely to be lacking, without the customer survey included in this submission, ETA will lack valuable feedback on the outcomes of TBL training program participants. In addition, were this survey not administered, ETA would lack data on participant motivations for participation and their satisfaction with programs and services.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances that would cause this information collection to be conducted in any manner listed above. Therefore, this request is consistent with 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

A Notice was published in the Federal Register on March 19, 2010 (Vol. 75, page 13305), as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

To ensure high response rates to the customer survey, several strategies will be employed. These will include sending a pre-notification letter explaining the study, making the questionnaire available both online and via mailed paper surveys, and contacting potential respondents multiple times to encourage a response.

An additional strategy to encourage responses and acknowledge that participation is not without some burden will be to offer a gift card for completing the survey. As a token of appreciation, respondents who complete the survey will be given a $15 gift card from an online merchandiser that can be redeemed for goods on that merchandiser’s website. This design is consistent with research that shows providing post-completion incentives are useful in promoting both respondent response to and retention in online surveys.

Recent evidence indicates that individuals are more likely to respond to (Cobanoglu and Cobanoglu, 2003) and are less likely to drop out of (O’Neil et al., 2003) online surveys when a post-payment incentive is provided than when it is not. Additional evidence from a meta-analysis of thirty-two incentive experiments using online surveys indicates that promised incentives promote both survey response and retention (Göritz, 2006).

Since the Internet is the primary method being used to administer the customer survey, the use of incentives is expected to aid in the achievement of a high response rate. By increasing response rates to the online survey solicitation, the provision of an incentive will help keep the evaluation within budget as the financial expense of following up with non-responders via telephone can be great.

Additionally, because incentives promote respondent retention, it is important provide a token of appreciation for completing this survey, in particular. Because the survey aims to gather information about both pre-training and post-training employment, questions about pre-training employment and income are asked early. Questions such as these are typically located at the end of surveys because they can be more sensitive and can cause survey break-off. Thus, it is important to try to mitigate the necessity of asking income and employment questions close to the beginning by providing an incentive, which, as research has shown, helps encourage respondents to finish online surveys.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

ETA’s contractor will work to assure and maintain the confidentiality of TBL programs’ participants. Administrative data records will be stripped of Social Security numbers prior to transmission from grantees to the contractor. For the purposes of linking administrative and survey data, other identifiers will be used that are unique to participants from a given grantee, such as student identification number. All other data items that identify participants will be kept by the contractor for use in assembling data and contacting respondents for the survey. Any data received by ETA will not contain personal identifiers, which will thus preclude individual identification.

In addition, the following safeguards are routinely used by the contractor to assure confidentiality in the collection of survey data:

• Access to contact information with personal identifying information is limited to those staff members that have direct responsibility for administering the survey.

• Identifying information is maintained in a separate file from interview data. The files are only linked with a respondent identification number.

• Access to link-files containing respondent identification numbers connecting the research data and the respondents’ identification is limited to a few persons who have a need to know this information. Moreover, the file will be encrypted using strong encryption when not in use.

• Access to any hard-copy documents is strictly limited. Physical precautions include use of locked files and cabinets, and shredders for discarded materials.

Persons to whom the questionnaire is distributed will be assured that their cooperation is entirely voluntary and that their responses will be held in the strictest confidence. Further, they will be assured that no data will be released to the public at-large, except in aggregate form, so that no individual’s response will be identified. Questionnaire responses will be collected and processed by the contractor for this evaluation, and the contractor will follow rigorous procedures for assuring and maintaining respondents’ confidentiality. Electronic data from online surveys will be maintained in a secure database and access to any data with identifying information will be limited to contractor staff members working directly on the evaluation.

In addition, in keeping with the Confidential Information Protection and Statistical Efficiency Act of 2002, the following statement has been added to each of the web-based and hard-copy questionnaires:

“Please note that your answers will be kept strictly confidential and will only be reported after combining your responses with those of all other respondents so that no individual person can be identified. In accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002 (Title 5 of Public Law 107-347) and other applicable Federal laws, your responses will not be disclosed in identifiable form without your informed consent. This voluntary information request has been approved by the Office of Management and Budget under OMB approval number 1205-XXXX, expiring xx/xx/xxxx. Without this approval, we would not be able to conduct this survey. Questions regarding any aspect of this survey may be directed to the U.S. Department of Labor, Employment and Training Administration, Room N-5641, 200 Constitution Avenue, N.W., Washington, D.C. 20210 (Paperwork Reduction Project 1205-XXXX).”

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

While none of the survey questionnaire items involves content of a sensitive nature, the evaluation will request administrative data from grantees that may include some information of a sensitive nature (i.e., participants’ age, race/ethnicity, and disability status). This request will include only data grantees have already collected from participants and will not require the gathering of additional information.

Obtaining these data from grantees will allow the evaluation analysis to investigate possible variation in outcomes for participant subgroups, especially those concerning traditionally underserved populations. This is particularly relevant to the evaluation as the Solicitation of Grant Applications for TBL Initiative grants encouraged applicants to engage populations not typically served by technology initiatives.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden OMB Form estimates for each form and aggregate the hour burdens in Item 13 of 83-I.

The total hour burden for information collected for TBL evaluation is 710 hours, as shown in Exhibit 3. The exhibit displays the respondent time burden for multiple collections of administrative data from each of the 20 grantees and for the customer survey. This hour burden is based on an estimate that it will take: 1) each grantee 2 hours of staff time each month during the period of survey administration to process administrative data requests for participants’ contact information; 2) each grantee 4 hours of staff time to process the one-time administrative data request for participant-level records containing demographic, enrollment, and outcomes information; and 3) each respondent 20 minutes to complete the customer survey. The time estimate for completing the customer survey has been verified by pilot testing of the survey with several respondents. The expected response rate is 70% (see Section B1).

Exhibit‑3: Respondent Hours Burden

Activity	Sample Size	Response Rate	Number of Respondents	Frequency	Time Per Response	Total Burden hours
Monthly Administrative Data Requests			20	7	120 minutes	280 hours
Final Administrative Data Request			20	Once	240 minutes	80 hours
Customer Survey	1,500	70%	1,050	Once	20 minutes	350 hours

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

The total annualized cost to respondents for all data collection activities is $17,991, as detailed in Exhibit 4. Since many of the grantees are government entities, the cost to grantees for administrative data collections is based on mean wages for likely respondents— state employees with the occupation classification of Network and Computer Systems Administrators—which according to the May 2008 National Occupational Employment and Wages Estimates compiled by the Bureau of Labor Statistics is calculated at $30.22.³ Thus, the total annualized cost to grantees for processing all administrative data requests is approximately $10,879.

The total annualized cost for the customer survey is $7,112. Since participants are likely to come from varied employment backgrounds, this estimated annualized cost for participants is based on the mean hourly wage for all occupations according to the May 2008 National Occupational Employment and Wages Estimates compiled by the Bureau of Labor Statistics, calculated at $20.32.⁴ However, this cost burden would be assuaged by the respondent incentive for completing the survey ($15 gift card).

Exhibit‑4: Annualized Cost for Respondent Hours Burden

Activity	Total hours	Average Hourly Wage	Total Annualized Cost
All Administrative Data Requests	360 hours	$30.22	$10,879
Customer Survey	350 hours	$20.32	$7,112

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

The proposed data collection for the customer survey will not require the respondents to purchase equipment or services or to establish new data retrieval mechanisms. ETA’s contractor will cover postage costs for all correspondence, including the return mailing of completed questionnaires. Survey content is based on respondents’ experiences, opinions, and factual information. Therefore, the cost to respondents solely involves time spent answering questions on the survey. Record keepers will not be necessary for this collection.

1. There will be no total capital or start-up costs.

2. It is not expected that there will be operation, maintenance, or purchase costs.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

Wide variances in the cost estimates are not expected for conducting this data collection.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

Respondents are not expected to purchase equipment or services in order to respond to this data collection effort.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

The total cost to the Federal Government of collecting administrative data and administering the customer survey is $121,517. This amount includes the cost of coordinating the collection of administrative data with grantees; designing the survey; developing the online survey; identifying the respondents; copying data collection materials; mailing the surveys and reminders; conducting telephone follow-up with non-respondents; coding, editing and keying the completed surveys; data analysis; and $20,400 for incentive payments.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

This is a new, one-time request that will count as 710 hours towards ETA’s Information Collection Budget.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The evaluation of TBL Grants began in March 2009. Customer surveys will be mailed to the first wave of exiting TBL program participants shortly after OMB clearance has been obtained, which is anticipated to be in early 2011. From that point, surveys may be distributed a second time to a subsequent group of exiting TBL program participants. Depending on the period of the evaluation, data collection will end in October 2011, just prior to the close of the evaluation period.

Participants’ survey responses will be matched to the participant-level data collected from grantees’ administrative data systems. Analyses will primarily entail the tabulation of these data, so that characteristics and outcomes of TBL participants can be profiled and customer satisfaction can be discussed. Results from this data collection will be presented in a final evaluation report, to be submitted to ETA in late 2011 or early 2012, depending on the length of the evaluation. Subsequent to passing through ETA’s internal clearance process, the final evaluation report will be made available to the public.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The OMB approval number and expiration date will be displayed or cited, in written correspondence or directives. This approval number will be prominently displayed on the survey itself.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

There are no exceptions to the certification statement.

1 Job seekers include participants in refresher courses, entry-level, un/underemployed, etc.

2 Grantees are only required to submit quarterly reports containing: 1) aggregate-level data on participant demographics, enrollment, and outcomes (Form ETA-9134); and 2) Standardized Individual Records, which include only Social Security number, employment status at participation, date of program exit, and reason for exit.

3 Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment Statistics, accessed 7/15/2009, http://www.bls.gov/oes/2008/may/naics4_999200.htm.

4 Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment Statistics, accessed 7/15/2009, http://www.bls.gov/oes/2008/may/oes_nat.htm#b00-0000.

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