ELS 2002 3rd-Follow-up 9-9 2012 Field Test Batch Tracing Part A

ELS 2002 3rd-Follow-up 9-9 2012 Field Test Batch Tracing Part A.doc

Education Longitudinal Study (ELS) 2002, Third Followup 2011 Field Test Batch Tracing

OMB: 1850-0652

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June 2010




Education Longitudinal Study: 2002

(ELS:2002)


Third Follow-up


Supporting Statement

Part A






Supporting Statement Request

For OMB Review

OMB# 1850-0652 v.5













Submitted by

National Center for Education Statistics

Institute of Education Sciences

U.S. Department of Education

Table of Contents



Section Page


Appendix 1. Affidavit of Nondisclosure Confidentiality Agreement 1-1

Appendix 2. Locating Update Letters and Forms 2-1

Appendix 3. IRB Approval Letter 3-1




List of Exhibits

A-1. Education Longitudinal Study:2002 (ELS:2002) second follow-up Technical Review Panel 17

A-2. ELS:2002 third follow-up data collection data security plan outline 22

A-3. Estimated sample maintenance burden on respondents for field test study (2011) and main study (2012) 25

A-4. Total costs to NCES 26

A-5. Operational schedule for ELS:2002/12 field test and full-scale activities 27

B-1. Tracing and Sample Maintenance Schedule for the Third follow-up Sample B-5

B-2. Consultants on statistical aspects of ELS:2002 B-7

B-3. Other contractor staff responsible for conduct of ELS:2002 B-7




PREFACE

This request concerns the third follow-up of the ELS:2002, an ongoing longitudinal study with a field test in 2011 and a full-scale data collection in 2012. This document requests clearance for selected early study activities (specifically direct locating and contacting of individual respondents or their parents) and general clearance of the ELS:2002 third follow-up data collection. These requests are submitted under the Paperwork Reduction Act of 1995 and 5 CFR 1320. The “Education Longitudinal Study of 2002” (ELS:2002) is being conducted by the Research Triangle Institute (RTI) under contract to the U.S. Department of Education (Contract number ED-04-CO-0036/0004).

This submission requests specific clearance of a procedure for updating contact information for members of the field test and full-scale samples of the third follow-up of the ELS:2002 longitudinal study. The request includes an experiment to determine the effectiveness of a payment of a small incentive when update information is supplied during the field test before proceeding with the full-scale study sample.

Secondly, this submission requests basic clearance of the ELS:2002 third follow-up as a sequel to the base year (2002) through second follow-ups (2006), which were previously cleared and completed but for which clearance has now expired.

A subsequent fully documented clearance request will be made to obtain OMB approval for the field test questionnaires, incentive experiments to be implemented in the data collection phase of the project, estimated burden to respondents for the field test and full scale studies, and a request for a waver of a 60-day federal register notice for the full scale study clearance in 2011. Additionally, generic clearance for cognitive testing of new or revised questionnaire items was requested separately, in a June 2010 submission (field test) and may be requested, if needed, in the September 2011 submission (full-scale) under OMB# 1850-0803.

The ELS:2002 study involves computer-assisted data collection (web, telephone, and field) with sample members who participated in the base-year or first follow-up ELS:2002 study (a subset of whom also participated in the second follow-up). The study may also involve the collection of financial aid information and postsecondary education transcripts for the cohorts in 2013-14. If the two optional components are approved, full details will be submitted to the Office of Management and Budget (OMB) in a future clearance package.

In this supporting statement, we report the purposes of the study, review the overall design, and describe the field test and full-scale panel maintenance or locating procedures and address how the collected information addresses the statutory provisions of the Education Sciences Reform Act of 2002 (P.L. 107-279). Subsequent sections of this document respond to OMB instructions for preparing supporting statements. Section A addresses OMB’s specific instructions for justification and provides an overview of the study’s design. Again, the draft questionnaire will be submitted at a later time, consonant with the need for content approval for the field test questionnaire data collection. Section B describes the collection of information and statistical methods.

A. JUSTIFICATION OF THE STUDY

A.1. Circumstances Making Collection of Information Necessary

A.1.a. Purpose of this Submission

The materials in this document support a request for clearance to conduct the third follow-up of the Education Longitudinal Study of 2002 (ELS:2002). The key specific study activity identified in this request and for which approval is specifically sought are the locating and recruiting activities to be conducted with sample members. The basic components and key design features of ELS:2002 are summarized below.

Base Year

  • Baseline survey of high school sophomores, in spring term 2002 (field test in spring term 2001).

  • Cognitive tests in Reading and Mathematics.

  • Parents and English and math teachers were surveyed in the base year. School administrator questionnaires were collected.

  • Additional components for this study include a school facilities checklist and a media center (library) questionnaire.

  • Sample sizes of about 750 schools and approximately 17,600 students (15,300 base-year respondents). Schools are first-stage unit of selection, with sophomores randomly selected within schools.

  • Oversampling of Asian Americans, private schools.

  • Design linkages (test concordances) with other assessment programs: Program for International Student Assessment (PISA); National Assessment for Educational Progress (NAEP) and test score reporting linkages to the prior longitudinal studies.


First Follow-up

  • Follow-up in spring 2004 (spring 2003 for field test), when most sample members were seniors, but some were dropouts or in other grades.

  • Student questionnaires, dropout questionnaires, cognitive tests, school administrator questionnaires administered.

  • Returned to the same schools, but separately followed transfer students.

  • Sample members no longer in school followed by telephone (computer-assisted telephone interview; CATI) or field (computer-assisted personal interview; CAPI) data collection.

  • Freshening for a nationally representative senior cohort.

  • High school transcript component in fall/winter, 2004–05 (2003–04 for field test).

Second Follow-up

  • Follow-up in spring 2006 (spring 2005 for field test) using web-based self-administered instrument with telephone (CATI) and field (CAPI) data collection for nonresponse follow-up.

  • Focus on transition to postsecondary education, labor force participation and family formation, with emphasis on postsecondary access and choice.

Third Follow-up

  • Follow-up in summer 2012 (summer 2011 field test) using web-based self-administered instrument with telephone (CATI) and field (CAPI) data collection for nonresponse follow-up.

  • Options may be exercised to collect postsecondary transcripts and financial aid records.

  • Focus on postsecondary education, labor force participation and family formation, with emphasis on college persistence and attainment.

The third follow-up study will provide data to map and understand the final outcomes of the high school cohorts’ transition to adult roles and statuses at about age 26. For the cohort as a whole, the third follow-up will obtain information that will permit researchers and policymakers to better understand issues of postsecondary persistence and attainment, as well as sub-baccalaureate (and to a more limited degree, baccalaureate) rate of economic and noneconomic return on investments in education. The third follow-up will also provide information about high school completion (for students who dropped out or were held back) and the status of dropouts, late completers, and students who have obtained an alternative credential, such as the GED. Finally, for both college-bound and non–college-bound students, the third follow-up will map their labor market activities and family formation.

For many cohort members, complex pathways, with alternative timings and durations for work and postsecondary enrollment, may be followed at this point of transition. In the 6-year period since the previous round, a sample member may both have worked and attended school, either serially or simultaneously; a cohort member may have attended school part-time or full-time and combined education and work spells with marriage and family formation. The singular strength of longitudinal studies is their power to provide data on transitions that are both complex and of some duration. The transition from adolescence to adult roles—and in particular, the transition to and through postsecondary education, and to labor force activity, and family formation—is of this very type.

A.1.b. Legislative Authorization

The National Center for Education Statistics (NCES) of the Institute of Education Sciences (IES), U.S. Department of Education, is conducting this study, as authorized under Section 151 of the Education Sciences Reform Act of 2002 (P.L. 107-279), which states:

  1. Establishment—There is established in the Institute a National Center for Education Statistics (in this part referred to as the ``Statistics Center'').

  2. Mission—The mission of the Statistics Center shall be—

    1. to collect and analyze education information and statistics in a manner that meets the highest methodological standards;

    2. to report education information and statistics in a timely manner; and

    3. to collect, analyze, and report education information and statistics in a manner that—

      1. is objective, secular, neutral, and nonideological and is free of partisan political influence and racial, cultural, gender, or regional bias; and

      2. is relevant and useful to practitioners, researchers, policymakers, and the public.

  3. General Duties—The Statistics Center shall collect, report, analyze, and disseminate statistical data related to education in the United States and in other nations, including—

    1. collecting, acquiring, compiling (where appropriate, on a State-by-State basis), and disseminating full and complete statistics (disaggregated by the population characteristics described in paragraph (3)) on the condition and progress of education, at the preschool, elementary, secondary, postsecondary, and adult levels in the United States, including data on—

  1. State and local education reform activities;

  2. State and local early childhood school readiness activities;

  3. student achievement in, at a minimum, the core academic areas of reading, mathematics, and science at all levels of education;

  4. secondary school completions, dropouts, and adult literacy and reading skills;

  5. access to, and opportunity for, postsecondary education, including data on financial aid to postsecondary students;

  6. teaching, including—

    1. data on in-service professional development, including a comparison of courses taken in the core academic areas of reading, mathematics, and science with courses in noncore academic areas, including technology courses; and

    2. the percentage of teachers who are highly qualified (as such term is defined in section 9101 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 7801)) in each State and, where feasible, in each local educational agency and school;

  7. instruction, the conditions of the education workplace, and the supply of, and demand for, teachers;

  8. the incidence, frequency, seriousness, and nature of violence affecting students, school personnel, and other individuals participating in school activities, as well as other indices of school safety, including information regarding—

    1. the relationship between victims and perpetrators;

    2. demographic characteristics of the victims and perpetrators; and

    3. the type of weapons used in incidents, as classified in the Uniform Crime Reports of the Federal Bureau of Investigation;

  9. the financing and management of education, including data on revenues and expenditures;

  10. the social and economic status of children, including their academic achievement;

  11. the existence and use of educational technology and access to the Internet by students and teachers in elementary schools and secondary schools;

  12. access to, and opportunity for, early childhood education;

  13. the availability of, and access to, before-school and after-school programs (including such programs during school recesses);

  14. student participation in and completion of secondary and postsecondary vocational and technical education programs by specific program area; and

  15. the existence and use of school libraries;

    1. conducting and publishing reports on the meaning and significance of the statistics described in paragraph (1);

    2. collecting, analyzing, cross-tabulating, and reporting, to the extent feasible, information by gender, race, ethnicity, socioeconomic status, limited English proficiency, mobility, disability, urban, rural, suburban districts, and other population characteristics, when such disaggregated information will facilitate educational and policy decisionmaking;

    3. assisting public and private educational agencies, organizations, and institutions in improving and automating statistical and data collection activities, which may include assisting State educational agencies and local educational agencies with the disaggregation of data and with the development of longitudinal student data systems;

    4. determining voluntary standards and guidelines to assist State educational agencies in developing statewide longitudinal data systems that link individual student data consistent with the requirements of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6301 et seq.), promote linkages across States, and protect student privacy consistent with section 183, to improve student academic achievement and close achievement gaps;

    5. acquiring and disseminating data on educational activities and student achievement (such as the Third International Math and Science Study) in the United States compared with foreign nations;

    6. conducting longitudinal and special data collections necessary to report on the condition and progress of education;

    7. assisting the Director in the preparation of a biennial report, as described in section 119; and

    8. determining, in consultation with the National Research Council of the National Academies, methodology by which States may accurately measure graduation rates (defined as the percentage of students who graduate from secondary school with a regular diploma in the standard number of years), school completion rates, and dropout rates.

Activities for ELS:2002 are included in Part 1 (A, C–K, M–O), Part 2, Part 3, Part 6, and Part 7.

The Center assures participating individuals and institutions that any data collected under the ELS:2002 study shall be in total conformity with NCES’s standards for protecting the privacy of individuals. Section 183 states that:

  1. In General—All collection, maintenance, use, and wide dissemination of data by the Institute, including each office, board, committee, and center of the Institute, shall conform with the requirements of section 552a of title 5, United States Code, the confidentiality standards of subsection (c) of this section, and sections 444 and 445 of the General Education Provisions Act (20 U.S.C. 1232g, 1232h).

  2. Student Information—The Director shall ensure that all individually identifiable information about students, their academic achievements, their families, and information with respect to individual schools, shall remain confidential in accordance with section 552a of title 5, United States Code, the confidentiality standards of subsection (c) of this section, and sections 444 and 445 of the General Education Provisions Act (20 U.S.C. 1232g, 1232h).

  3. Confidentiality standards are—

  1. IN GENERAL that

  1. The Director shall develop and enforce standards designed to protect the confidentiality of persons in the collection, reporting, and publication of data under this title.

  2. This section shall not be construed to protect the confidentiality of information about institutions, organizations, and agencies that receive grants from, or have contracts or cooperative agreements with, the Federal Government.

  1. With PROHIBITIONS that no person may—

  1. Use any individually identifiable information furnished under this title for any purpose other than a research, statistics, or evaluation purpose;

  2. Make any publication whereby the data furnished by any particular person under this title can be identified; or

  3. Permit anyone other than the individuals authorized by the Director to examine the individual reports.

Any person who uses any data provided by the Director, in conjunction with any other information or technique, to identify any individual student, teacher, administrator, or other individual and who knowingly discloses, publishes, or uses such data for a purpose other than a statistical purpose, or who otherwise violates subparagraph (a) or (B) of subsection (c) (2), shall be found guilty of a class E felony and imprisoned for not more than five years, or fined as specified in Section 3571 of title 18, United State Code, or both.

The confidentiality of ELS:2002 data is further regulated by the USA Patriot Act of 2001 and the E-Government Act of 2002, as well as the Privacy Act of 1974 and the Computer Security act of 1987.

A.1.c. Prior and Related Studies

In 1970 NCES initiated a program of longitudinal high school studies. Its purpose was to gather time-series data on nationally representative samples of high school students, which would be pertinent to the formulation of and evaluation of educational polices.

Starting in 1972 with the National Longitudinal Study of the High School Class of 1972 (NLS:72), NCES began providing longitudinal data to educational policymakers and researchers that linked educational experiences with later outcomes such as early labor market experiences and postsecondary education enrollment and attainment. The NLS:72 cohort of high school seniors was surveyed five times (in 1972, 1973, 1974, 1979, and 1986). A wide variety of questionnaire data were collected in these follow-up surveys, including data on students’ family background, schools attended, labor force participation, family formation, and job satisfaction. In addition, postsecondary transcripts were collected.

Almost 10 years later, in 1980, the second in a series of NCES longitudinal surveys was launched, this time starting with two high school cohorts. High School and Beyond (HS&B) included one cohort of high school seniors comparable to the seniors in NLS:72. The second cohort within HS&B extended the age span and analytical range of NCES’ longitudinal studies by surveying a sample of high school sophomores. With the sophomore cohort, information became available to study the relationship between early high school experiences and students’ subsequent educational experiences in high school. For the first time, national data were available showing students’ academic growth over time and how family, community, school, and classroom factors promoted or inhibited student learning. In a leap forward for educational research, researchers, using data from the extensive battery of cognitive tests within HS&B, were also able to assess the growth of cognitive abilities over time. Moreover, data were now available to analyze the school experiences of students who later dropped out of high school. These data became a rich resource for policymakers and researchers over the next decade and provided an empirical base to inform the debates of the educational reform movement that began in the early 1980s. Both cohorts of HS&B participants were resurveyed in 1982, 1984, and 1986. The sophomore cohort was also resurveyed in 1992. Postsecondary transcripts also were collected for both cohorts.

The third longitudinal study of students sponsored by NCES was the National Education Longitudinal Study of 1988 (NELS:88). NELS:88 further extended the age and grade span of NCES longitudinal studies by beginning the data collection with a cohort of eighth-graders. Along with the student survey, it included surveys of parents, teachers, and school administrators. It was designed not only to follow a single cohort of students over time (as had NCES’s earlier longitudinal studies NLS­­:72 and HS&B), but also, by “freshening” the sample at each of the first two follow-ups, to follow three multiple nationally representative grade cohorts over time. Eighth-grade, 10th-grade, and 12th-grade cohorts, thus, were included in the study series. This provided not only comparability of NELS:88 to existing cohorts, but it enabled researchers to conduct both cross-sectional and longitudinal analyses of the data. Additionally, in 1993, high school transcripts were collected for each student, further increasing the analytic potential of the survey system. Consequently, NELS:88 represents an integrated system of data that tracked students from middle school through secondary and postsecondary education, labor market experiences, and marriage and family formation.

In design, ELS:2002 recapitulates the sophomore cohort of HS&B. However, in terms of the richness of its contextual data sources, particularly its coverage of school-level, curricular, and home environmental factors, ELS:2002 is most similar to NELS:88, and for this reason a more detailed description of the 1988 study is provided below.

The base-year survey for NELS:88 was carried out during the spring semester of the 1987–88 academic year. The study employed a clustered, stratified national probability sample of 1,052 public and private eighth-grade schools. Almost 25,000 students across the United States participated in the base-year study. Questionnaires and cognitive tests were administered to each student in the NELS:88 base year. The student questionnaire covered school experiences, activities, attitudes, plans, selected background characteristics, and language proficiency. School principals completed a questionnaire about the school; two teachers of each student were asked to answer questions about the student, about themselves, and about their school; and one parent of each student was surveyed regarding family characteristics and student activities.

The first follow-up of NELS:88, conducted in 1990 or 2 years after the base-year study, included the same components as the base-year study, with the exception of the parent survey. Additionally, a “freshened” sample was added to the student component to achieve a representative sample of the nation’s sophomores. Some 18,221 students participated (of 19,363 selected), with 1,043 dropouts taking part (of 1,161 identified), for a total of 19,264 participating students and dropouts. In addition, 1,291 principals took part in the study, as did nearly 10,000 teachers.

The second follow-up for the cohort took place early in 1992, when most sample members were in the second semester of their senior year of high school. The second follow-up provided a culminating measurement of learning in the course of secondary school, and also collected information that facilitated the investigation of the transition into the labor force and postsecondary education after high school. Because the NELS:88 longitudinal sample was freshened to represent the 12th-grade class of 1992, trend comparisons were possible between the senior cohorts from the 1972, 1980, and 1982 school years from the NLS:72 and HS&B. The NELS:88 second follow-up resurveyed students who were identified as dropouts in 1990, and identified and surveyed the additional students who had left school since the prior wave.

NELS:88/1994, the third follow-up wave of the eighth-grade class of 1988, took place during the spring semester of the 1993–94 school year. In 1994, most of the sample members had already graduated from high school, and many had begun postsecondary education or entered the workforce. The study addressed issues of employment and postsecondary access, and was designed to allow continuing trend comparisons with other NCES longitudinal studies. For the first time in the sequence of NELS:88 studies, the primary form of data collection was individual CATI interviews, with personal interviews completed with selected respondents requiring intensive tracking and nonresponse refusal conversion.

The fourth follow-up of the eighth-grade class of 1988 (NELS:88/2000) interviewed the sample cohort in the spring and summer of 2000 when the respondents were typically 25 to 26 years old, approximately 12 years after the base-year data collection. Postsecondary transcripts for this cohort were collected primarily in the autumn of 2000, with the last cases worked early in 2001. Data collection commenced approximately 6 years after the last contact with the sample, enabling researchers to explore a new set of educational and social issues about the NELS:88 respondents. At the time of the fourth follow-up, most of the participants in the various cohorts of NELS:88 had been out of high school for 8 years. At this age, most students who intend to enroll in postsecondary education have done so. A large proportion had achieved an undergraduate degree by 2000, some had completed graduate or professional programs. A postsecondary transcript component was added to NELS:88/2000 to collect the educational records of sample members who entered postsecondary education. By then many of these young people had married and had children of their own; some were be divorced; some had become successful in the marketplace; and some were still struggling to transition to the work force and to develop their own career.

HSLS:09. Finally, although not a prior study, the High School Longitudinal Study of 2009 is a related NCES study, and indeed, the successor study to ELS:2002. It began with a nationally representative sample of public and private schools in the fall of 2009, and a student sample of entering high school freshmen. HSLS:09 ninth-graders will be resurveyed in 2012, 2013, 2015, and 2021. The base-year survey includes school administrators, counselors, science teachers, math teachers, and counselors. HSLS:09 is similar in its objectives to the other high school longitudinal studies, but places greater emphasis on choice behaviors associated with coursetaking and careers in science, technology, engineering, and mathematics (STEM) than did prior studies.

A.2. Purposes and Use of ELS:2002

ELS:2002 is intended to be a general purpose data set; that is, it is designed to serve multiple policy objectives. Broadly speaking, the third follow-up interview will focus on postsecondary education, work experiences, family formation, and community involvement. Topics related to education will build on the theme of collecting data on access to postsecondary that was initiated in the second follow-up, where extensive data on all college applications submitted by sample members was obtained, to include a range of new issues, concerning students’ persistence and attainment in postsecondary education. This new data will include information about the amounts of different types of student aid received from various sources over their entire college experience, and from college transcripts from all colleges attended a complete record of all the courses they enrolled in and the grades they received. Some new data will also be collected on the dynamics of jobs they have entered into and their progress in finding and forming a promising career. In addition, special attention will be given to high school dropouts’ progress toward a high school diploma, GED, or other equivalency, including GED test score information. Since some sample members will have chosen not to continue their education in the 2 years following high school, a series of questions will focus upon experiences in the workforce. Yet, because another group of respondents will have been going to school and working, work and educational histories over the six years since last interview must be covered. In addition to collecting factual information about educational enrollments and work experiences, the interview will collect information on respondents’ basic life goals. As sample members turn 26 years of age, the modal age of the participants at the time of the interview, marriage and parenthood become more common. Therefore, the third follow-up is the appropriate time to determine which participants have started forming families. With regard to community involvement, participation in volunteer work, and the political process will be examined. All final outcomes must be collected in this round, in the compass of a relatively brief (30-minute) interview.

The objectives of ELS:2002 also encompass the need to support both longitudinal and cross-cohort analyses, and to provide a basis for important descriptive cross-sectional analyses. ELS:2002 is first and foremost a longitudinal study, hence survey items are chosen for their usefulness in predicting or explaining future outcomes as measured in later survey waves. At the same time, ELS:2002 content should, to the extent possible, be kept comparable to that of the prior NCES high school studies, to facilitate cross-cohort comparisons (for example, trends over time can be examined by comparing 1980, 1990, and 2002 high school sophomores; or 1972, 1980, 1982, 1992, and 2004 high school seniors). The 2012 (third follow-up) round of ELS:2002 can be compared to the year 2000 round of NELS:88, when cohorts from both studies will be, typically, 8 years beyond high school graduation.

Content justifications and the questionnaire itself will be presented to OMB after the field test questionnaire has been developed.

A.3. Improved Information Technology

The principal innovation for ELS:2002 that represents a technological improvement over the data collection methods used in the predecessor study, NELS:88, is in applying computer methods to the data collection. ELS:2002 second follow-up used a web-enabled survey system to program the instrument for self-administered, CATI, and CAPI modes. The survey instrument was indistinguishable in terms of screen text and skip patterns in each of the three survey modes. The only difference among the three modes was whether a telephone or field interviewer administers the survey. The advantages of a web-based instrument include real-time data capture and access, including data editing in parallel with data collection, and increased efficiencies in effecting timely delivery. This same approach—successfully used in the 2006 round—will also be used in the ELS:2002 third follow-up.

Additional features of the system include (1) online help for each screen to assist in question administration; (2) full documentation of all instrument components, including variable ranges, formats, record layouts, labels, question wording, and flow logic; (3) capability for creating and processing hierarchical data structures to eliminate data redundancy and conserve computer resources; (4) a scheduler system to manage the flow and assignment of cases to interviewers by time zone, case status, appointment information, and prior cases disposition; (5) an integrated case-level control system to track the status of each sample member across the various data collection activities; (6) automatic audit file creation and timed backup to ensure that, if an interview is terminated prematurely and later restarted, all data entered during the earlier portion of the interview can be retrieved; and (7) a screen library containing the survey instrument as displayed to the respondent (or interviewer).

A.4. Efforts to Identify Duplication

Since the inception of its secondary education longitudinal program in 1970, NCES has consulted with other federal offices to ensure that the data collected in the series do not duplicate other national data sources. The inclusion on the Technical Review Panels for ELS:2002 of both of members of the research community and of other government agencies helps to focus study and instrument design on features of youth transition that ELS:2002 uniquely can illuminate.

ELS:2002 does not duplicate, but temporally extends, the prior NCES longitudinal studies—NLS:72, HS&B, and NELS:88.

Other NCES studies involve assessments of similar age groups to ELS:2002 (PISA 15-year-olds, NAEP eighth-graders and high school seniors), but are not longitudinal, and do not collect data from parents. By the time of the second follow-up (2006, when most sample members were out of high school for 2 years), there is some similarity in sample to the NCES BPS. However, the BPS longitudinal study focuses only on beginning postsecondary students, including late entrants into the system. In contrast, ELS:2002 includes both cohort members who go onto postsecondary education and others who do not—but misses late entrants to the system, because it will not follow sample members past age 26. Thus BPS and ELS:2002 are fundamentally complementary, not duplicative.

The only non-NCES federal study that would appear to be comparable to ELS:2002 is the BLS National Longitudinal Survey of Youth (NLSY)—the NLSY79 and, sampling respondents closer to ELS:2002 in age, the NLSY97 shares with ELS:2002 (and the prior NCES high school cohorts) the goal of studying the transition of adolescents into adult roles. However, NLSY is an age cohort while ELS:2002 is a grade cohort, and NLSY is household-based while ELS:2002 is school-based. Although both studies are interested in both education and labor market experiences (and their interrelationship), ELS:2002 puts more emphasis on postsecondary education, while NLSY stresses labor market outcomes and collects detailed employment event histories. Thus, similarly as with BPS, ELS:2002 and the two NLSY cohorts are complementary rather than duplicative.

A.5. Methods Used to Minimize Burden on Small Businesses

This section has limited applicability to the proposed data collection effort. Target respondents for ELS:2002 are individuals, and direct data collection activities via web-based self-administration, CATI, and CAPI will involve no burden to small businesses or entities. Small entities such as high schools are no longer included in the data collection scheme. However, should the financial aid and postsecondary transcripts options be exercised, the data collection would involve some small entities (defined as proprietary or not-for-profit postsecondary institutions enrolling fewer than 1,000 students). The update memo covering these options would also address issues of burden minimization for small entities.

A.6. Frequency of Data Collection

This submission describes sample maintenance (tracing) activities for the field test and full-scale survey of ELS:2002 third follow-up, in the larger context of the purposes and procedures of the study. One design element that is central to fulfilling the purpose of the study is the frequency or periodicity of data collection.

The rationale for conducting ELS:2002 is based on a historical national need for information on academic and social growth, school and work transitions, and family formation. In particular, recent education and social welfare reform initiatives, changes in federal policy concerning postsecondary student support, and other interventions necessitate frequent studies. Repeated surveys are also necessary because of rapid changes in the secondary and postsecondary educational environments and the world of work. Indeed, longitudinal information provides better measures of the effects of program, policy, and environmental changes than would multiple cross-sectional studies.

To address this need, NCES began the National Longitudinal Studies Program approximately 40 years ago with the National Longitudinal Study of the High School Class of 1972 (NLS:72). This study collected a wide variety of data on students’ family background, schools attended, labor force participation, family formation, and job satisfaction at five data collection points through 1986. NLS:72 was followed approximately 10 years later by High School and Beyond (HS&B), a longitudinal study of two high school cohorts (10th- and 12th-grade students). The National Education Longitudinal Study of 1988 (NELS:88) followed an 8th-grade cohort, which now, with a modal age of 26 years, represents the probable final data collection point. With the addition of ELS:2002, a 32-year trend line will be available. Taken together, these studies provide much better measures of the effects of social, environmental, and program and policy changes than would a single longitudinal study or multiple cross-sectional studies.

It could be argued that more frequent data collection would be desirable; that is, there would be a gain in having a program of testing and questionnaire administration that is annual throughout the high school years. However, the 2-year interval was employed with both the HS&B sophomore cohort and NELS:88, and proved sufficient to the realization of both studies’ primary objectives. Although there would be benefits to more frequent data collection, especially in the high school years, it must also be considered that the effect would be to greatly increase the burden on schools and individuals, and that costs would also be greatly increased. Probably the most cost-efficient and least burdensome method for obtaining continuous data on student careers through the high school years comes through the avenue of collecting school records. High school transcripts were collected for a subsample of the HS&B sophomore cohort, as well as for the entire NELS:88 cohort retained in the study after eighth grade. A similar academic transcript data collection (covering grades 9 through 12) was conducted for the first follow-up of ELS:2002.

Periodicity of the survey after the high school years (at the very terminus of the study) may also be questioned—there is a 6-year gap between the 2006 round (2 years out of high school) and the final round in 2012 (8 years out of high school). Undoubtedly, more process and postsecondary education context information could be obtained if there were surveys in the intervening years. However, the strategy of waiting until about age 26 for the final re-interview is extremely cost-effective, in that the information collected at that time includes both final outcomes and statuses, and provides a basis for identifying the postsecondary institutions that individual sample members have attended. In turn, postsecondary transcripts are then obtained that provide continuous enrollment histories for specific courses taken, and provide records of course grades and other information needed to analyze postsecondary persistence and attainment.

A.7. Special Circumstances of Data Collection

All data collection guidelines in 5 CFR 1320.5 are being followed. No special circumstances of data collection are anticipated.

A.8. Consultants Outside the Agency

The 60-day Federal Register notice was published on May 6, 2010 (75 FR, No. 87, p. 24935). We have received no public comments in response to this notice.

In recognition of the significance of ELS:2002, several strategies have been incorporated into the project’s work plan that allow for the critical review and acquisition of comments regarding project activities, interim and final products, and projected and actual outcomes. These strategies include consultations with persons and organizations both internal and external to the National Center for Education Statistics, the U.S. Department of Education, and the federal government.

ELS:2002 project staff are establishing a Technical Review Panel (TRP) to review study plans and procedures. The third follow-up TRP will include some of the earlier ELS:2002 panelists for continuity with prior phases of the study. However, the membership is being reconstituted to reflect the shift in focus from high school experiences to postsecondary and labor market transitions that mark the final outcomes of the study. The prior (second follow-up) ELS:2002 TRP (see Exhibit A-1 for a list of the TRP membership and their affiliations) represented a broad spectrum of federal and nonfederal experts in secondary and postsecondary education, labor market transitions and outcomes, and high school effectiveness research. Additionally, the TRP included members of panels from earlier NCES longitudinal high school studies such as NELS:88.

Exhibit A-1. Education Longitudinal Study:2002 (ELS:2002) second follow-up Technical Review Panel

Participants and Staff Contact List


Technical Review Panel


Clifford Adelman

U.S. Department of Education

Institute of Education Sciences

550 12th Street, SW

Potomac Center Plaza -- Room 11110

Washington, DC 20065

Voice: (202) 245-7805

E-mail: [email protected]


Frank Balz

National Association of Independent Colleges & Universities

1025 Connecticut Avenue, NW

Washington, DC 20036

Voice: (202) 785-8866

E-mail: [email protected]


Nancy Broff

Career College Association

10 G Street, NE, Suite 750

Washington, DC 20002-4213

Voice: (202) 336-6755

E-mail: [email protected]



Alisa Cunningham

The Institute for Higher Education Policy

1320 19th Street, NW

Washington, DC 20036

Voice: (202) 861-8223

E-mail: [email protected]


Richard Duran

University of California at Santa Barbara

Graduate School of Education

2206 Phelps Hall

Santa Barbara, CA 93106

Voice: (805) 893-3555

E-mail: [email protected]


Jeremy Finn

State University of New York at Buffalo

Graduate School of Education

409 Baldy Hall

Buffalo, NY 14260

Voice: (716) 645-2484

E-mail: [email protected]



James Griffith

U.S. Department of Education, NCES

1990 K Street, NW -- Room 8103

Washington, DC 20006

Voice: (202) 502-7387

E-mail: [email protected]


Thomas Hoffer

NORC

University of Chicago

1155 East 60th Street

Chicago, IL 60637

Voice: (773) 256-6097

E-mail: [email protected]


Lisa Hudson

U.S. Department of Education, NCES

1990 K Street, NW -- Room 9035

Washington, DC 20006

Voice: (202) 502-7358

E-mail: [email protected]


Sally Kilgore

Modern Red Schoolhouse

1901 21st Avenue, South

Nashville, TN 37212

Voice: (615) 320-8804

E-mail: [email protected]


Jacqueline King

American Council on Education

One Dupont Circle, NW -- Suite 800

Washington, DC 20036

Voice: (202) 939-9559

E-mail: [email protected]


Samuel Lucas

University of California-Berkeley

410 Barrows Hall #1980

Berkeley, CA 94720

Voice: (510) 642-9564

E-mail: [email protected]


Andrew Malizio

U.S. Department of Education, NCES

1990 K Street, NW -- Room 8091

Washington, DC 20006

Voice: (202) 219-7006

E-mail: [email protected]


Edith McArthur

U.S. Department of Education, NCES

1990 K Street, NW -- Room 9115

Washington, DC 20006

Voice: (202) 502-7393

E-mail: [email protected]


David Miller

American Institutes for Research

Education Statistics Services Institute

1990 K Street, NW, Suite 500

Washington, DC 20006

Voice: (202) 403-6533

E-mail: [email protected]


Catherine Millett

Educational Testing Service

Policy Evaluation & Research Center

Rosedale Road, Mailstop 01-R

Princeton, NJ 08542

Voice: (609) 734-5866

E-mail: [email protected]


Jeffrey Owings

U.S. Department of Education, NCES

1990 K Street, NW -- Room 9105

Washington, DC 20006

Voice: (202) 502-7423

E-mail: [email protected]


Aaron Pallas

Teachers College, Columbia University

525 West 120th Street

Box 3

New York, NY 10027

Voice: (212)678-8119

E-mail: [email protected]


Kent Phillippe

American Association of Community Colleges

One Dupont Circle, NW - Suite 410

Washington, DC 20036

Voice: (202) 728-0200, Ext. 222

E-mail: [email protected]


Michael Ross

U.S. Department of Education, NCES

1990 K Street, NW -- Room 9101

Washington, DC 20006

Voice: (202) 502-7443

E-mail: [email protected]



Leslie Scott

American Institutes for Research

Education Statistics Services Institute

1990 K Street, NW, Suite 500

Washington, DC 20006

Voice: (202) 654-6542

E-mail: [email protected]


Marilyn Seastrom

U.S. Department of Education, NCES

1990 K Street, NW -- Room 9051

Washington, DC 20006

Voice: (202) 502-7303

E-mail: [email protected]


Marsha Silverberg

U.S. Department of Education

555 New Jersey Avenue, NW

Washington, DC 20208

Voice: (202) 208-7178

E-mail: [email protected]


Dawn Terkla

Tufts University

28 Sawyer Avenue

Institutional Research

Medford, MA 02155

Voice: (617) 627-3274

E-mail: [email protected]


Vincent Tinto

Syracuse University

School of Education

353 Huntington Hall

Syracuse, NY 13244-2340

Voice: (315) 443-3343

E-mail: [email protected]


John Wirt

U.S. Department of Education, NCES

1990 K Street, NW -- Room 9028

Washington, DC 20006

Voice: (202) 502-7478

E-mail: [email protected]


RTI International


Laura Burns

RTI International

PO Box 12194

Research Triangle Park, NC 27709

Voice: (919) 990-8318

E-mail: [email protected]


Douglas Currivan

RTI International

PO Box 12194 - 3040 Cornwallis Road

Research Triangle Park, NC 27709

Voice: (919) 316-3334

E-mail: [email protected]


Steven Ingels

RTI International

701 13th Street, NW

Washington, DC 20007

Voice: (202) 974-783

E-mail: [email protected]


Daniel Pratt

RTI International

PO Box 12194

Research Triangle Park, NC 27709

Voice: (919) 541-6615

E-mail: [email protected]


John Riccobono

RTI International

PO Box 12194

Research Triangle Park, NC 27709

Voice: (919) 541-7006

E-mail: [email protected]


Peter Siegel

RTI International

PO Box 12194

Research Triangle Park, NC 27709

Voice: (919) 541-6348

E-mail: [email protected]


A.9. Provision of Payments or Gifts to Respondents

This topic—as it pertains to incentives for questionnaire completion—will be discussed at length in the full regular clearance request for the field test and full-scale study. However, this submission, covering clearance for early panel maintenance activities, includes a proposal for a locating phase experiment, in which a monetary incentive is distributed to cooperating students or their parents. Given the dispersion of this mobile young adult sample between 2006 and 2012 (2005 and 2011 for the field test), locating sample members will be a critical factor in the success of the ELS:2002 third follow-up.

Incentive experiment. The incentive experiment concerning locating for panel maintenance may be concisely explained. In the sample maintenance communication, half of the students in the field test sample will be offered a $10 check if they (or their parents) confirm or update their contact information. The sample will be categorized as student-parent pairs and assignment to treatment (offer of $10) and control group (no offer of remuneration) will be random. Text will also appear in the communication to parents, alerting them to the offer. Students will be mailed the $10 check upon receipt of their confirmation or updated information (regardless of who, the student or the parent, provided the students’ contact information).

While a test of the positive statistical significance of the difference between the treatment and control group on this dimension would provide a basis for assessing the effectiveness of the incentive, and such a test will be calculated, a more comprehensive approach also will be conducted. It will include a cost-benefit analysis that takes into account the incentive effect relative to the range of outcomes relative to differences in difficulty and cost. If the additional update information comes overwhelmingly from the least problematic (or “easy-to-track”) cases, the benefit is not as great as it would be if information for more difficult cases were obtained. Analysis therefore will take into account the various statuses: no information (e.g., undeliverable/no forwarding address), delivered or forwarding address but no confirmation obtained, provided or confirmed a new address, or confirmed the old address. In addition, specific elements of information—whether fields for new/existing telephone numbers, e-mail addresses etc. are filled in—can be compared for those who received an incentive versus those who did not. The ultimate judgment criterion will be whether the cost of the incentive is more than offset by the cost of locating without the incentive. If this incentive procedure is deemed effective, we recommend that it be implemented when the next set of sample maintenance materials are sent to the full-scale sample in Summer 2011.

A.10. Assurance of Confidentiality

RTI will deliver to NCES a data security plan (DSP) for the ELS:2002 third follow-up data collection in September 2010. The ELS:2002 third follow-up data collection plan will strengthen confidentiality protection and data security procedures developed for prior rounds of ELS:2002 and represent best-practice survey systems and procedures for protecting respondent confidentiality and securing survey data. An outline of this proposed and to-be-submitted plan is provided in Exhibit A-2. The ELS:2002 third follow-up data collection DSP will

  • establish clear responsibility and accountability for data security and the protection of respondent confidentiality with corporate oversight to ensure adequate investment of resources;

  • detail a structured approach for considering and addressing risk at each step in the survey process and establish mechanisms for monitoring performance and adapting to new security concerns;

  • include technological and procedural solutions that mitigate risk and emphasize the necessary training to capitalize on these approaches; and

  • be supported by the implementation of data security controls recommended by the National Institute of Standards and Technology for protecting federal information systems.

Exhibit A-2. ELS:2002 third follow-up data collection data security plan outline

ELS:2002 Data Security Plan Summary

Maintaining the Data Security Plan

Information Collection Request

Our Promise to Secure Data and Protect Confidentiality

Personally Identifying Information That We Collect and/or Manage

Institutional Review Board Human Subject Protection Requirements

Process for Addressing Survey Participant Concerns

Computing System Summary

General Description of the RTI Networks

General Description of the Data Management, Data Collection, and Data Processing Systems

Integrated Monitoring System

Receipt Control System

Instrument Development and Documentation System

Data Collection System

Document Archive and Data Library

Employee-Level Controls

Security Clearance Procedures

Nondisclosure Affidavit Collection and Storage

Security Awareness Training

Staff Termination/Transfer Procedures

Subcontractor Procedures

Physical Environment Protections

System Access Controls

Survey Data Collection/Management Procedures

Protecting Electronic Media

Encryption

Data Transmission

Storage/Archival/Destruction

Protecting Hard-Copy Media

Internal Hard-Copy Communications

External Communications to Respondents

Handling of Mail Returns, Hard-Copy Student Lists, and Parental Consent Forms

Handling and Transfer of Data Collection Materials

Tracing Operations

Software Security Controls

Data File Development: Disclosure Avoidance Plan

Data Security Monitoring

Survey Protocol Monitoring

System/Data Access Monitoring

Protocol for Reporting Potential Breaches of Confidentiality

Specific Procedures for Field Staff

Under this plan, the ELS:2002 third follow-up data collection will conform totally to federal privacy legislation, including

  • the Privacy Act of 1974 (5 U.S.C. 552a);

  • Section C of Education Sciences Reform Act of 2002 (P.L. 107-279);

  • the USA Patriot Act of 2001 (P.L. 107-56);

Consistent with the Privacy Act, these data will constitute a system of records, per the system of records notice 18-13-01 National Center for Education Statistics Longitudinal Studies and the School and Staffing Surveys (64 FR, No. 107, p. 30181-82, June 4, 1999).

More specifically, it is expected that ELS:2002 will conform to the NCES Restricted Use Data Procedures Manual and NCES Standards and Policies. The plan for maintaining confidentiality includes obtaining signed confidentiality agreements and notarized nondisclosure affidavits from all personnel who will have access to individual identifiers (see Appendix 1 for copies of these forms). Each individual working in ELS:2002 will also complete the e-QIP clearance process. The security plan includes annual personnel training regarding the meaning of confidentiality and the procedures associated with maintaining confidentiality, particularly as it relates to handling requests for information and providing assurance to respondents about the protection of their responses. The training will also cover controlled and protected access to computer files under the control of a single database manager; built-in safeguards concerning status monitoring and receipt control systems; and a secured and operator-manned in-house computing facility.

The sample maintenance recruiting materials (the letters appear in Appendix 2) have been reviewed and approved (see Appendix 3) by RTI’s Committee for the Protection of Human Subjects prior to sample selection. This committee serves as RTI’s Institutional Review Board (IRB) as required by 45 CFR 46. It is RTI policy that all RTI research involving human subjects, regardless of funding source, undergoes IRB review in a manner consistent with the regulations in 45 CFR 46 to ensure that all such RTI studies comply with applicable regulations concerning informed consent, confidentiality, and protection of privacy.

In later phases of the field test and full-scale study, further letters will be sent to sample members to initiate data collection and offer access to the web survey. These letters will describe the voluntary nature of the survey. The materials sent will include a brochure describing the study, the ways the data will be used, and conveying the extent to which the identity of the respondents and their responses will be kept confidential. The pre-notification letter to the study will contain the following statements:

Your answers may be used only for statistical purposes and may not be disclosed, or used, in identifiable form for any other purpose except as required by law [Education Sciences Reform Act of 2002 (ESRA 2002) Public Law 107-279, Section 183].”

During the telephone interview, the following informed consent statement will be read verbatim. We have slightly modified the language used in this passage to more accurately reflect a telephone/personal contact.

As mentioned in the letter, you previously participated in ELS:2002 with about 15,000 other students across the country who were selected from 10th-grade classes in 2002 or 12th-grade classes in 2004. This survey is part of an education research study sponsored by the U.S. Department of Education. The purpose of ELS:2002 is to provide information that will be used to improve the quality of education in America. The interview will ask questions about your further schooling and work experiences. On average, it takes about 30 minutes to complete, depending on your responses.

Participation is voluntary. Your answers may be used only for statistical purposes and may not be disclosed, or used, in identifiable form for any other purpose except as required by law [Education Sciences Reform Act of 2002 (ESRA 2002) Public Law 107-279, Section 183]. You may withdraw from the study at any point. However, your answers are very important because they represent many others who were not selected to take part. You may skip any question that you don’t want to answer.”

Data files, accompanying software, and documentation will be delivered to NCES at the end of the project. Neither names nor addresses will be included on any data file. A separate locator database for these sample members will be maintained in a secure location. All hard-copy tracing directory updates will be destroyed after they are entered into magnetic form and verified.



A.11. Sensitive Questions

Federal regulations governing the administration of questions that might be viewed by some as “sensitive” because of their requirement for personal or private information, require (a) clear documentation of the need for such information as it relates to the primary purpose of the study, (b) provisions to respondents which clearly inform them of the voluntary nature of participation in the study, and (c) assurances of confidential treatment of responses. Because the content choices for the third follow-up round have not yet been made, information about sensitive questions, if any are selected, will be included in the field test clearance submission to OMB.

A.12. Estimates of Hour Burden for Information Collection for Sample Maintenance in the Field Test and Full-scale Study

Estimates of response burden for the ELS:2002 third follow-up field test and full-scale study sample maintenance (tracing) activities are shown in Exhibit A-3.

Exhibit A-3. Estimated sample maintenance burden on respondents for field test study (2011) and main study (2012)




Sample

Expected Response
Rate

Number of Respondents

Average Burden/
Response (minutes)

Range of Response Times (minutes)

Total
Burden (hours)

Field Test (2011)

1,060

20%

212

5 minutes

----

18 hours

Full-scale Study (2012), 1

16,200

20%

3,240

5 minutes

----

270 hours

Full-scale Study (2012), 2

16,200

20%

3,240

5 minutes


270 hours

The “sample” column represents the number of student cohort members who serve as the unit of analysis—update information will be obtained for an estimated one fifth (20 percent) of this sample, regardless of whether the information comes from the student or from the parent. For the full-scale study, there will be two sample maintenance contacts, one in October 2010 and a second 1 year later.

Included in the notification letter will be the following burden statement:

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The valid OMB control number of this information collection is 1850-0652 and it is completely voluntary. The interview will be no more than 35 minutes in length. If you have any comments concerning the accuracy of the time estimate or suggestions for improving the interview, please write to: U.S. Department of Education, Washington, DC 20202-4651. If you have comments or concerns regarding the status of your individual interview, write directly to: Dr. John Wirt, National Center for Education Statistics, 1990 K Street NW, Washington, DC 20006.”


A.13. Estimates of Costs

There are no capital, startup, or operating costs to respondents for participation in the project. No equipment, printing, or postage charges will be incurred.

Estimated costs to the federal government for ELS:2002 are shown in Exhibit A-4. The estimated costs to the government for data collection for the third follow-up field test and full-scale studies are presented separately. Included in the contract estimates are all staff time, reproduction, postage, and telephone costs associated with the management, data collection, analysis, and reporting for which clearance is requested.

A.14. Costs to Federal Government

Exhibit A-4. Total costs to NCES

Costs to NCES

Amount

Total ELS:2002/12 costs


Salaries and expenses

$200,000

Contract costs

$9,647,075

Total Annual ELS:2002/12 cost

$3,282,358

NOTE: All costs quoted are exclusive of incentive fee.

A.15. Reasons for Changes in Response Burden and Costs

This is a reinstatement of a previously approved collection. The program change of 558 burden hours is due to the reinstatement as well as the addition of the batch tracing letters and information update request form.

A.16. Publication Plans and Time Schedule

The ELS:2002/12 field test will be used to test and improve the instrumentation and associated procedures. Publications and other significant provisions of information relevant to the data collection effort will be a part of the reports resulting from the full-scale study, and both public use and restricted use data files will be important products. The ELS:2002 data will be used by public and private organizations to produce analyses and reports covering a wide range of topics. With the third follow-up, ELS:2002 data will add a fourth point in time for longitudinal analysis, and extend the cross-cohort comparison to predecessor cohorts (NELS:88, HS&B, and NLS-72).

Data files will be distributed to a variety of organizations and researchers, including offices and programs within the U.S. Department of Education, the Congressional Budget Office, the Department of Health and Human Services, Department of Labor, Department of Defense, the National Science Foundation, the American Council on Education, and a number of other education policy and research agencies and organizations. The ELS:2002 contract requires the following reports, publications, or other public information releases:

  • detailed methodological reports (one each for the field test and full-scale survey – in the form of a comprehensive Data File Documentation Report covering the base year through the third follow-up, with an appendix for the field test) describing all aspects of the data collection effort;

  • complete restricted-use, longitudinal full-scale study data files and documentation for research data users, including postsecondary institution transcript data and potentially financial aid information;

  • corresponding public-use data files for public access to ELS:2002 base year to third follow-up results; and

  • a “first look” summary of significant descriptive findings for dissemination to a broad audience (the analysis deliverable will include technical appendices).

Final deliverables for the third follow-up are scheduled for completion in 2013. (Final deliverables for the transcript study are scheduled for completion in 2015.) The operational schedule for the ELS:2002 third follow-up field test and full-scale study is presented in Exhibit A-5.

Exhibit A-5. Operational schedule for ELS:2002/12 field test and full-scale activities

Activity

Start

End

Field test



Panel maintenance: contact updates for sample

9/2010

6/2011

First round of cognitive testing of items

8/2010

9/2010

Data collection

7/2011

12/2011

Second round of cognitive testing

10/2011

12/2011

Full-Scale Study



Panel maintenance: contact updates for sample

9/2010

6/2012

Data collection

7/2012

1/2013

Transcript and Student Aid Data



Pilot testing of operations

2/2013

8/2013

Transcript and student aid data collection

8/2013

3/2014

Transcript keying and coding

11/2013

8/2014


A.17. Approval to Not Display Expiration Date for OMB Approval

The expiration date for OMB approval of the information collection will be displayed on data collection instruments and materials. No special exception to this requirement is requested.

A.18. Exception to Certification for Paperwork Reduction Act Submissions

No exceptions are requested to the certification statement identified in the Certification for Paperwork Reduction Act Submissions of OMB Form 83-I.

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