Supporting Statement for Paperwork Reduction Act Submission
Part A
Transition and Postsecondary Programs for Students with Intellectual Disabilities (TPSID) Evaluation System
July 13, 2011
Submitted to:
Office of Postsecondary Education
U.S. Department of Education
1990 K Street
Washington, D.C. 20006-8524
Project Officer: Shedita Alston
Submitted by:
Institute for Community Inclusion
University of Massachusetts Boston
100 Morrissey Blvd.
Boston, MA 02125
Project Director: Debra Hart
Contents
A. Justification 23
1. Circumstances Necessitating Collection of Information 23
2. Purposes and Uses of Data 3
3. Secondary analysis for research purposes 5
3. Use of Technology to Reduce Burden 54
4. Efforts to Avoid Duplication of Effort 5
5. Methods of Minimizing Burden on Small Entities 65
6. Consequences of Not Collecting Data 65
7. Special Circumstances 6
8. Federal Register Announcement and Consultation 6
9. Payment or Gift to Respondents 67
10. Confidentiality of the Data 7
11. Additional Justification for Sensitive Questions 7
12. Estimates of Hours Burden 78
13. Estimate of Total Annual Cost Burden to Respondents or Recordkeepers 78
14. Estimates of Annualized Cost to the Federal Government 79
15. Reasons for Program Changes or Adjustments 108
16. Tabulation, Publication Plans, and Time Schedules 810
17. Approval Not to Display the Expiration Date for OMB Approval 911
18. Exception to the Certification Statement 911
Appendix A: Higher Education Opportunities Ac (HEOA) Amendments of 2008 1012
The U.S. Department of Education (ED) is requesting Office of Management and Budget (OMB) clearance for the Transition and Postsecondary Programs for Students with Intellectual Disabilities (TPSID) Evaluation System. This system will be used to evaluate the implementation and outcomes of the five-year Transition Programs for Students with Intellectual Disabilities (TPSIDs) model demonstration projects. This evaluation is being conducted by the Institute for Community Inclusion, University of Massachusetts Boston, under contract with ED (contract number P407B100002).
The main objectives of this project are: (1) Establishment of a uniform dataset for collection of required program data from 27 TPSID demonstration project grantees and their partner sites across the country; (2) use of the program data for a national evaluation of the TPSID program; and (3) secondary analysis of the program data for research purposes.
This request seeks clearance for establishment of a uniform dataset across all TPSID sites (including both grantees and partner sites) to ensure consistency in collection of information.
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.
In October 2010, the Department of Education, Office of Postsecondary Education (OPE) awarded 27 institutes of higher education (IHE) grants to fund the creation of Transition Programs for Students with Intellectual Disabilities (TPSIDs) (model demonstrations) in 23 states. The Department of Education grant applications for TPSID grantees under CFDA #: 84.407A indicated:
…that in accordance with Section 767(d)(5) of the HEA, grantees would be required to participate in evaluation activities conducted by the coordinating center established by section 777(b) of the HEA. As part of these reports and evaluation activities, grantees will be expected to work closely with the coordinating center to develop performance measures most closely aligned with activities that promote the successful transition of students with disabilities into higher education (page 37).
It further stated that TPSID grantees would be asked to regularly collect and provide 11 GPRA performance measures to the Coordinating Center.
The Office of Postsecondary Education TPSID Program awarded one (1) Model Comprehensive Transition and Postsecondary Programs for Students with Intellectual Disabilities Coordinating Center (TPSIDCC) to build a valid and reliable knowledge base around program components.
The TPSIDCC Coordinating Center’s involvement in data collection related to the TPSID demonstration will establish of uniform dataset across all TPSID sites (including both grantees and partner sites) to ensure consistency in collection of information comprised by the 11 required GPRA measures. To accomplish this coordination the of data collection, the Coordinating Center intends to collect these program data at the institution and individual level from TPSID and partner site program staff via an online, secure, data management system.
The TPSIDCC is also Second, the Coordinating Center is charged with conducting an evaluation of the 27 TPSID programs. The Coordinating Center’s evaluation effort intends to address the following evaluation questions:
What academic, independent living, career development, and social opportunities are TPSIDs providing to participants enrolled in their programs?
What are the outcomes for participants who attend TPSID programs and how do these outcomes vary based on personal characteristics?
How do participants' outcomes in TPSIDs vary based on program characteristics?
How have the TPSIDs' activities changed over during the project period?
What kinds of internal and external collaboration activities are staff from TPSIDs conducting?
What activities do TPSIDs conduct with the families?
What existing campus resources/ college systems do students served by TPSIDs use?
What type of credential is each TPSID offering and how are TPSIDsS tracking progress towards this credential?
What kinds of evaluation activities are the TPSIDs conducting?
What funding mechanisms are being used by TPSIDs and students?
What vehicles are the TPSIDs using to enhance sustainability?
To ward this end, each year after the July 31 deadline, Coordinating Center staff will summarize the evaluation data provided for the preceding year; all data will also be summarized at the conclusion of the five-year project. Data analysis will take place using SPSS and will consist primarily of descriptive and frequency analyses.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe any consideration given to using technology to reduce burden.
This system allows TPSIDs and their partners to fill in data as they become available from any computer that has access to thewith Internet access.
Given the longitudinal nature of the project, a web-based evaluation system reduces burden by allowing TPSID and partner site staff to review the previous year's data and makeing updates and changes as needed, rather than completing entering a full set an entire set of annual data without reference to previous entries.
Intuit Quickbase, which supports a relational database platform, reduces respondent burden by storing data that will need to be called on by TPSIDs for multiple records rather than requiring them to continuously enter similar information into many records.
This system facilitates the use of nested levels of analysis (i.e. a number of individual students within each TPSID or partner program).
This system provides a secure mechanism for transmittal of data.
The system is available for TPSIDs to both enter and retrieve data on their programs, allowing them to use this system to facilitate other reporting requirement such as their Annual Performance Reports.
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.Efforts to Avoid Duplication of Effort
In order to obtain funding each year from the Office of Postsecondary Education, each TPSID must provide these data. The role of the proposed data collection system is to standardize the data collection process to make it more efficient and useful both to the TPSIDs and to the OPE. Moreover, the system was designed to facilitate collection, storage, and retrieval of data in support of TPSIDs' required Annual Performance Reports to the Department of Education.
Since this grant program is new, comparable information on these programs is not available from any other source. We did investigate other data sources and do plan to gather a considerable portion of background information (program demographics) from the Integrated Postsecondary Education Data System (IPEDS; http://nces.ed.gov/ipeds/). Finally, we took great pains during instrument development to avoid replication; for example, no question is asked on the program level if it can be calculated from the student level data.
No small businesses are involved in this effort; only institutes of higher education will be entering data in the system.
The goal of OPE’s TPSID Program is to promote the successful transition of students with intellectual disabilities into higher education and to enable institutions of higher education (or consortia of institutions of higher education), to create or expand high quality, inclusive model comprehensive transition and postsecondary programs for students with intellectual disabilities. Without this consistent, centralized data collection system, OPE would not be able to evaluate the impact of this program as a whole; additionally it would be difficult to ascertain which types of programs or approaches were most successful at achieving the intended outcomes of inclusive education and gainful employment. Program statute also requires this data collection.
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 than 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 that 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.
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 instruction and record keeping, 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 60 day and 30 day notice was published in the Federal Register for public comment.
The Department of Education has consulted with persons outside the agency in the development of this data collection system. Key project staff from the Institute for Community Inclusion are:
Debra Hart
Principal
Investigator
[email protected]
Meg Grigal, Ph.D.
Co-Principal Investigator
[email protected]
Frank A. Smith
Evaluation Coordinator
[email protected]
Draft versions of the data collection instruments (both Program and Student level) were sent to all of the TPSIDs' Principal Investigators in February 2011. Respondents were asked to review the data elements and provide feedback both on individual questions and on the instruments as a whole. Nineteen of the twenty-seven TPSIDs provided feedback on the Program tool and eighteen of twenty-seven TPSIDs provided feedback on the Student tool. The extensive comments received were reviewed in detail by project staff in March 2011 and changes to the system were made based on that feedback.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts are being made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
No student names will be stored in the database, and individual student- level program data will be assigned unique ID number to allow Coordinating Center staff to differentiate between records. Only approved TPSID model demonstration project staff and partner site staff (as assigned by the TPSID Principal InvestigatorI) will have access to the key that relates names to assigned ID numbers.
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. The 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.
No questions of a sensitive nature are included.
12. 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 estimates for each form and aggregate the hour burdens in item 16 of IC Data Part 1.
Provide estimates of annualized cost to respondents of 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 14.
A total of 56 IHEs (the 27 TPSID grantees plus 29 partner sites) will be required to enter data in the system annually.
Since the time required to enter data in the system is heavily dependent on the number of students in the program, the time required will vary considerably from school to school. Based on our pilot testing experience to date, we expect a TPSID program to need 2 1/2 hours to complete the program-level data collection and 1 1/2 hours to complete each student record. Based on TPSIDs' projections of numbers of students they expect to enroll, we expect the 56 TPSIDs to serve an average of 631 students each year. Therefore, the expected data entry time for each year is 140 hours for program data (2.5 x 56) and 946.5 hours for student data (1.5 x 631), for a total yearly data entry time of 1,086.5 hours.
We also asked a small sample of pilot test participants for their hourly cost of staff time for data entry and the average hourly cost was $31. Based on that average rate, the 1,086.5 hours of burden costs responding TPSIDs a total of $33,682.
13. Provide an estimate of 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 acquiring and maintaining record storage facilities.
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 contracting out information collection 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.
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.
Total Annualized Capital/Startup Cost :
Total Annual Costs (O&M) :
____________________
Total Annualized Costs Requested :
TPSIDs should be able to complete this data reporting using existing computer equipment, so no additional cost burden beyond the staff resources is expected.
14. Provide estimates of annualized cost 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 also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
The estimated cost to the federal government for this data collection activity over the next three years is $228,773, distributed as outlined in Table 1.
Table 1 Cost to federal government
Year 1 (system design and startup costs) |
2011 |
$41,347 |
Year 2 |
2012 |
93,713 |
Year 3 |
2013 |
93,713 |
Total over 3 years |
|
$228,773 |
A more detailed tabulation of costs is provided in Table 2.
Table 2 Specific tabulation of costs
Initial startup costs (6 months, Jan-June, 2011) |
|
.6 FTE Research Associate |
$18,600 |
.2 FTE Research Study Coordinator |
4,060 |
.2 FTE Research Associate |
4,810 |
.1 FTE PI |
4,980 |
.1 FTE Co-PI |
4,750 |
Consultant fees |
1,600 |
3 months Quickbase service at $849/mo. |
2,547 |
Total startup costs |
$41,347 |
|
|
Yearly ongoing costs |
|
.4 FTE Research Associate |
$25,679 |
.4 FTE Research Study Coordinator |
16,862 |
.4 FTE Research Associate |
19,924 |
.1 FTE PI |
9,960 |
.1 FTE Co-PI |
9,500 |
Consultant fees |
1,600 |
Quickbase service at $849/mo. |
10,188 |
Total costs per year |
$93,713 |
15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.
This is a new collection, therefore all burden is new. This program change results in an increase in burden of 1,087 hours and 56 responses.
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.
Each year after the data submission deadline, Coordinating Center staff will summarize the evaluation data provided for the preceding year; all data will also be summarized at the conclusion of the five-year project. Data analysis will take place using SPSS and will consist primarily of descriptive and frequency analyses. These data summaries will be provided to OPE in an annual report and published on the project web site. The data will also be used in presentations at national conferences (at least 3) and manuscript submissions to journals (at least 2).
In addition to the data summaries, the Coordinating Center also plans to perform secondary analysis of the program data to determine the relationships between characteristics and outcomes at both the program level and the individual level. This secondary data analysis will also take place using SPSS and will include inferential statistics such as correlation analysis, t-tests, and ANOVAs, as well as predictive analyses such as regression. Findings of the secondary analysis will be (1) used to develop a report and recommendations for OPE and the existing TPSID programs; (2) published in at least 2 journal articles and (3) presented at least 3 national conferences. Table 3 indicates the time schedule for the entire five-year project.
Table 3 Time schedule of project activities
Activity |
2011 |
2012 |
2013 |
2014 |
2015 |
|||||||||||||||
|
Q1 |
2 |
3 |
4 |
1 |
2 |
3 |
4 |
1 |
2 |
3 |
4 |
1 |
2 |
3 |
4 |
1 |
2 |
3 |
4 |
Development of data collection instruments |
X |
X |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Pilot testing and OMB review |
|
|
X |
X |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Data collection |
|
|
|
|
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
|
|
Closeout of year's data collection & data cleaning/followup |
|
|
|
|
|
|
X |
|
|
|
X |
|
|
|
X |
|
|
|
X |
|
Descriptive analyses and annual report |
|
|
|
|
|
|
|
X |
|
|
|
X |
|
|
|
X |
|
|
|
|
Secondary data analysis |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
X |
X |
X |
X |
|
Conference presentations |
|
|
|
X |
|
|
|
X |
|
|
|
|
|
X |
|
|
X |
|
X |
X |
Manuscripts submitted to journals |
|
|
|
|
|
|
X |
|
|
X |
|
|
|
X |
|
|
|
|
|
X |
Final report |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
X |
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.
We are not seeking approval to not display the expiration date for OMB approval.
18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.
There are no exceptions.
Section 767(d): USE OF FUNDS – An institution of higher education (or consortium) receiving a grant under this section shall use the grant funds to establish a model comprehensive transition and postsecondary program for students with intellectual disabilities that –
(5) participates with the coordinating center established under section 777(b) in the evaluation of the model program.
Section 777(b)(5) REQUIREMENTS OF COOPERATIVE AGREEMENT – The eligible entity entering into a cooperative agreement under this subsection shall establish and maintain a coordinating center that shall –
(C) develop an evaluation protocol for such programs that includes qualitative and quantitative methodologies for measuring student outcomes and program strengths in the areas of academic enrichment, socialization, independent living, and competitive or supported employment.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT |
| Author | Kenneth Smith |
| File Modified | 0000-00-00 |
| File Created | 2021-01-31 |