Response to OMB comments for prev 1875-NEW (4559) ICR currectly withdrawn

From:                              Mar, Sharon [[email protected]]

Sent:                               Monday, August 15, 2011 6:00 PM

To:                                   Ingalls, Katrina

Cc:                                   Axt, Kathy; Yeh, Beth

Subject:                          RE: #1875-NEW (4559) Changes due to Public Comment on the EHCY Program National Evaluation Data Collection #1875-NEW (4559)

 

Katrina/Kathy,

Thanks for getting us additional information.  Although ED��s responses provided a better explanation, we are still worried about the study��s primary research questions, data collection plan/description of the surveys, how those questions will answer the research questions proposed,  and the strategy for analyzing the data to answer those research questions (overall evaluation��s strategy). 

Since we are already nearing day 60 on this collection, it might make most sense to take this off the clock and have meetings with ED/OMB to better walk through the strategy and once we��ve got an agreed upon collection, ED can resubmit without going through additional comment periods (so long the evaluation has not changed dramatically since the previous public comment periods).

Please let me know your thoughts on this proposal.  Thanks,

 

 

 

Hi Sharon,

I will be out of the office until Wednesday the 17^th.  If you have further comments �V or want the revisions uploaded while I am out, please let Kathy Axt know. Kathy has the revised documents , etc., that will be needed to upload in my absence.  Thanks for your help.

Katrina

 

Hi Sharon,

Here are the sponsor��s answers to your questions.  Let me know if anything further is needed.  Thanks.

Katrina

 

 

Katrina-

Here is the response.

Beth

The first step in analysis will begin once the surveys are in OMB review.  The contractor will create a detailed analysis plan that will include table shells and chart mock-ups designed to address the research questions.  Creating the table shells and chart mock-ups will help identify and fine-tune the specific analyses required to address the research questions.   

 

With fully cleaned and weighted data, analysis will proceed, organized around the three research areas.  Basic frequencies will provide descriptive information on these three areas.  As appropriate, the contractor will develop scales that combine answers to several questions within each of the three areas of implementation; as a measure of the reliability of such scales, Cronbach��s alpha will be computed and reported.  Cross-tabulations will reveal differences in implementation associated with such variables as district size and geographic region and, of particular interest, differences found between districts that do and do not receive McKinney-Vento Homeless Assistance Act (MVHAA) funds.  For this and other analyses of differences, the appropriate statistical test (e.g., Chi-square, rank sum, or Cramer��s V) will be used.  Where the questions from the current state survey overlap with the previous two state surveys and where appropriate, PSA will directly compare tabulations across years to determine statistical differences. 

 

To address some of the research questions, such as how the role and responsibilities of the district liaison for subgrantee and non-subgrantee districts differ, the evaluators will use multiple linear regression to control for differences between the two groups that are not fully controlled through the matching process, like district size, or the tenure of the liaison in his or her position.  This will help discern the respective contributions of different variables, including whether a district is a subgrantee or non-subgrantee, to the observed differences.  For example, liaisons in districts receiving MVHAA funds may report spending their time differently on MVHAA-related activities than do liaisons in districts receiving no MVHAA funds.  Multiple regression will help determine to what extent these differences in time spent are due to differences in MVHAA funding, district size, length in position, or other factors.  

 

To provide a sense of the type of analysis that the study team will conduct, this evaluation plan presents examples applying the analysis techniques described above to address the three broad research areas.  This is not an exhaustive description of the analysis.

 

How are states and districts identifying the needs of homeless children and youth?  Using frequencies, the report will present the type of data states and district collect and the ways states and districts use the data.  The report will highlight the use of data for purposes beyond compliance such as program improvement.  Where there is a significant difference in how subgrantee and non-subgrantee districts use data, the evaluators will indicate whether this difference is statistically significant.  The evaluators anticipate that subgrantee districts will use data more extensively than do non-subgrantee districts.

 

Responses to the  state survey regarding the types of barriers homeless children and youth face will be compared to responses from the surveys for the previous two evaluations to see what changes in the types of barriers, if any, have occurred in the intervening years.  The CSPR will provide data from subgrantee districts on the most common barriers that homeless children and youth face and on the policies and services to address them and district surveys will provide more detailed data on these barriers and policies and services for all districts.  Descriptive data will show the commonalities and variation across districts.  Regression analysis will help discern the variables, such as district size, location, and receiving MVHAA funding that might account for any observed differences.

 

The state and district surveys will also ask likert scale questions on the level of awareness of relevant individuals in the SEA or LEA about the legislative requirements of MVHAA and the needs of homeless children and youth of individuals.

 

How are states and districts addressing the needs of homeless children and youth?  The report will use descriptive statistics to show which of their responsibilities the state coordinators and district liaisons see as most important, the average time that they spend carrying out these responsibilities, and the competing demands on their time.  The analysis will focus on the degree of variation across states and districts.  As discussed above, the evaluators will use regression analysis to show the relationship between, on the one hand, the variation in a liaison�� use of time and, on the other, whether a district receives MVHAA funds, the characteristics of the district, and the characteristics of the liaison.

 

The report will use state coordinator and district liaison responses to likert scale questions regarding their efforts toward coordination and collaboration.  To get a sense of specific examples of coordination and collaboration at the state and district levels, such as cross-training, sharing data, and sharing resources, the report will display frequencies of the state coordinators�� and district liaisons�� responses.  The evaluators will run cross-tabulations to see whether there are significant differences between subgrantee and non-subgrantee districts.  To see what accounts for these differences, the evaluators will run regression analysis.  Data collected from the SASA reports will also provide information on the state coordinators�� efforts to collaborate with other SEA program offices and state agencies.  The report will also examine the differences between the responses of the state coordinator and the aggregated responses of the district liaisons within the same state. 

 

What supports does the state provide to districts to help them address the needs of homeless children and youth?  Based on data collected from SASA monitoring reports and state surveys, the report will provide descriptive statistics on the ways states monitor (desk reviews versus site visits) district compliance with MVHAA requirements.  The state and district surveys will also ask respondents, in the case of the state, about the type of technical assistance provided or, in the case of the district, the usefulness of the technical assistance received.  Reponses to the technical assistance questions from the state coordinator and district liaisons in the same state will be compared and tested for statistical significance in order to gauge their respective views of technical assistance.  The report will show the percentage of states distributing MVHAA-ARRA funds using a formula compared to those distributing funds using a competitive application process, what percentage of regular and ARRA funds states reserve for themselves, and why districts do and do not apply for MVHAA grants.

 

 

 

Beth,

Could you provide Sharon with the information listed in the email below?  Please cc me on your response �V or send it to me and I will forward this to Sharon. Thanks.

 

Katrina

 

 

Katrina,

Can we get a description of the analysis that ED intends to conduct with the data they are collecting, including the methodology they��ll be using?

Thanks,

 

 

 

 

 

 

Hi Sharon,

As a result of a public comment received from Donna Bolt on July 14, 2011, the sponsor has made  slight wording changes to the District Survey and Notification letters. The copies of the revised District Survey and notification letters are attached. Let me know if you want these uploaded in Rocis at this point (I will need for you to open it)�V or if you want me to wait until you do the rest of your review and upload all changes at that point.  Thanks.

 

Katrina.

 

 

 

The district survey and notification letters were changed.  They are attached.

Beth

 

 

Beth,

Which instruments were changed?  Could you include the revised files in this email when you respond so I can send them to Sharon at OMB?  Thanks.

Katrina

 

 

 

Katrina-

We are making the following changes on the basis of this suggestion:

Clarifying the language in the district survey and e-mail to superintendents, state coordinators, and district liaisons to note that the district could be a grantee or a ��member of an intermediate educational agency or consortium receiving the grant��.  

Do you want me to upload these changes into EDICS?

Thanks,

Beth

 

Hi Beth,

Here is a public comment sent to OMB for your  collection.  Let us know if you plan to make changes based on the suggestion.  Thanks.

Katrina  

 

 

Good Morning, Katrina:

Please see below public comments regarding (4559) 1875-NEW ��Evaluation of the Education of Homeless Children and Youth Program.��

Kim

 

Attention: Education Desk Officer, OMB:

This is in regard to the request for comments on:

Evaluation of the Education for Homeless Children and Youth Program; OMB Control Number: 1875-NEW.

I am a State Coordinator for the EHCY program, and read the survey instructions that are going to Subgrantees of Homeless Education funds in each state.  I noticed that the survey is addressed to ��Districts�� �V assuming that a District Liaison is completing the survey as a subgrantee.

Please note that some states, such as Oregon, award some competitive subgrant funds to Consortia of Districts (e.g., districts applying together as a County Consortium).  The Consortia Lead may not be a District Liaison, but a program coordinator who is completing the survey on behalf of a number of districts that are under one subgrant.  There do not appear to be options for responses from Subgrantees that represent multiple districts.

Thanks for including this comment among those that are due by July 22.

Best,

Dona

Dona Bolt, State Coordinator
Homeless Education Program
Oregon Dept. of Education
255 Capitol St. NE
Salem OR 97310-0203

PH: 503-947-5781

 

The data collection instruments for the national evaluation for the Education for Homeless Children and Youth Program are available for public comment until July 22, 2011. The national evaluation will include surveys of state coordinators and local liaisons on items related to the implementation of the program. Please read the information provided below from the Office of Management and Budget on how to provide comments.

SUMMARY: The Acting Director, Information Collection Clearance Division, Privacy, Information and Records Management Services, Office of Management, invites comments on the submission for OMB review as required by the Paperwork Reduction Act of 1995 (Pub. L. 104-13).

DATES: Interested persons are invited to submit comments on or before July 22, 2011.

ADDRESSES: Written comments should be addressed to the Office of Information and Regulatory Affairs, Attention: Education Desk Officer, Office of Management and Budget, 725 17th Street, NW., Room 10222, New Executive Office Building, Washington, DC 20503, be faxed to (202) 395-5806 or e-mailed to [email protected] with a cc: to [email protected]. Please note that written comments received in response to this notice will be considered public records.

SUPPLEMENTARY INFORMATION: Section 3506 of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35) requires that the Office of Management and Budget (OMB) provide interested Federal agencies and the public an early opportunity to comment on information collection requests. The
OMB is particularly interested in comments which: (1) Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility; (2) Evaluate the accuracy of the agency's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used; (3) Enhance the quality, utility, and clarity of the information to be collected; and (4) Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

Dated: June 16, 2011.
James Hyler,
Acting Director, Information Collection Clearance Division, Privacy,
Information and Records Management Services, Office of Management.

Office of Planning, Evaluation and Policy Development

    Type of Review: New.
    Title of Collection: Evaluation of the Education for Homeless
Children and Youth Program.
    OMB Control Number: 1875-NEW.
    Agency Form Number(s): N/A.
    Frequency of Responses: Once.
    Affected Public: State, Local, or Tribal Government, State
Educational Agencies or Local Educational Agencies.
    Total Estimated Number of Annual Responses: 256.
    Total Estimated Annual Burden Hours: 151.
   

Abstract: The evaluation will survey state coordinators and district liaisons for Education for Homeless Children and Youth (EHCY) Program. The evaluation addresses research questions in the following areas of program implementation: (1) The collection and use of data on homeless children and youth; (2) the expenditure of EHCY Program funds; (3) the policies and services provided by local educational agencies to remove barriers that prevent homeless children and youth from accessing a free, appropriate public education; and (4) the coordination of such efforts at the local level.
    Copies of the information collection submission for OMB review may
be accessed from the RegInfo.gov <http://www.gpo.gov/fdsys/pkg/FR-2011-06-22/html/RegInfo.gov>  Web site at http://www.reginfo.gov/public/do/PRAMain or from the Department's Web site at http://edicsweb.ed.gov <http://edicsweb.ed.gov/> , by selecting the ``Browse Pending Collections'' link and by clicking on link number 4559. When you access the information collection, click on ``Download Attachments '' to view. Written requests for information should be addressed to U.S. Department of Education, 400 Maryland Avenue, SW., LBJ, Washington, DC 20202-4537. Requests may also be electronically mailed to the Internet address [email protected] or faxed to 202-401-0920. Please specify the complete title of the information collection and OMB Control Number when making your request.

 

Diana Bowman, Director
National Center for Homeless Education
SERVE Center at UNCG
336-315-7453
Website: www.serve.org/nche
Helpline: 800-308-2145