A. Justification
A. JUSTIFICATION
This is a request for Office of Management and Budget (OMB) clearance to collect data for the Chapter 33 Education (EDU) Longitudinal Study Survey. The first five years of this 20-year longitudinal study is being conducted for the Veterans’ Benefits Administration (VBA) under contract with Westat. The VBA, within the U.S. Department of Veterans Affairs (VA), is seeking approval for primary data collection for this important study.
1. Purpose and Authority
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.
Overview. On October 10, 2008, Congress passed the Veterans' Benefits Improvement Act (Public Law 110-389) to improve, enhance compensation and pension, housing, labor and education, and insurance benefits for Veterans. Section 334 of this law amended Chapter 31 by adding a 20-year longitudinal study requirement of Veterans who participated in the Vocational Rehabilitation and Employment (VR&E) VetSuccess program during fiscal years 2010, 2012, and 2014. In order to comply with the requirements of the law, VBA is conducting the VR&E Longitudinal Study Survey, a 20-year longitudinal survey of a random sample of VR&E participants who began the program in FY2010, FY2012, and FY2014.
Since its inception on August 1, 2009, many Veterans who exit the military with a service-connected disability exercise the option of using their Chapter 33 Post-9/11 GI Bill benefits (instead of Chapter 31 benefits) to further their education and improve their employment outcomes. In tandem with the Congressionally-mandated VR&E Longitudinal Study, VBA is conducting the companion Chapter 33 Education Longitudinal Study to assess the long-term outcomes of all Veterans participating in this program, including those with a service-connected disability. In order to fully understand the impact of these programs on the long-term educational and employment outcomes of Veterans with service-connected disabilities, VA needs to conduct both the VR&E Longitudinal Study and the Chapter 33 Education (EDU) Longitudinal Study. Additionally, the EDU Longitudinal Study will allow VBA to assess long-term outcomes of all Veterans who avail themselves of Chapter 33 benefits, not just those with service-connected disabilities. OMB approved the VR&E Longitudinal Study on August 31, 2012 (OMB Control Number: 2900-0786). This current request is for the EDU Longitudinal Study. The EDU Longitudinal Study is a 20-year longitudinal study on three cohorts of Veterans and their dependents who began using educational benefits authorized by the Post-9/11 GI Bill at some point in fiscal years 2010, 2012, and 2014. Eligible dependents include individuals receiving transferred benefits (spouse or child) and those who receive benefits as a result of the Fry scholarship.
Overall approach and goals. The primary goal of the EDU Longitudinal Study is to determine the longitudinal outcomes associated with participating in the educational assistance provided through the Chapter 33 program. The specific outcomes of interest are (1) education (2) employment, (3) income, (4) home ownership, and (5) use of (need for) other program benefits, measured by receipt of Social Security Disability Insurance (SSDI), unemployment benefits, or other public program benefits. As one’s life circumstances changes, repeated measures of employment and community adjustment over time are typically more meaningful, providing a more accurate picture of the individual’s employment situation.
The study will employ three sources of data to measure the outcomes and contributing factors of interest: (1) administrative data currently residing within VBA administrative files, (2) self-reported survey data to be collected, and (3) existing administrative data from the Social Security Administration (SSA) through the use of data sharing agreements. Using data from all three sources will allow for more comprehensive analyses that will provide better understanding of the long-term outcomes of Chapter 33 participants.
VBA administrative datasets have the advantage of including data elements that are available on an entire study cohort population (e.g., all Chapter 33 participants who began participation in FY2010, FY2012, or FY2014) for a given fiscal year. Similarly, inclusion of SSA administrative data will provide an objective data source for all cohort members receiving SSA benefits. However, the primary source of data that will be used to assess long-term outcomes of VR&E participants is the self-report survey data that will be collected annually.
Survey data will be collected from all cohort groups using a multi-modal data collection approach for the initial survey, as well as for the annual longitudinal followup surveys to be conducted for 20 years. While the primary focus of the survey data collection approach will be to collect the data as a web survey, a paper-pencil mail mode will be offered to those Veterans who do not complete the web survey, and computer-assisted telephone interviews (CATI) will be conducted with those Veterans who indicate they would prefer to complete the survey over the telephone.
Purpose of survey data collection activity. The main source of data that will be used to assess the long-term outcomes of Chapter 33 participants is the longitudinal survey data. No current data sources exist that provide the information needed to assess long-term employment and educational outcomes, thus initiating the need for this new data collection activity associated with the EDU Longitudinal Study. Data extracted from VBA administrative files will be used to build the sampling frames from which the three cohorts of survey participants will be randomly selected. These files will include relevant contact information for each cohort member, including mailing addresses, email addresses, and telephone numbers.
Table 1 lists the specific measures that will be used for analysis, and the respective data source associated with each measure. The table indicates that without the survey, VA will not have the data needed to properly assess the long-term outcomes of Chapter 33 participants. The initial survey instrument will be applicable for the first survey administration and the annual followup survey will be applicable for the next two years. Subsequent surveys will be developed to address that fact that some of the questions may no longer be relevant and/or applicable.
Domain |
Measure |
Source of Data |
Formula |
Survey Item |
Employment |
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Income |
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Education |
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Home ownership |
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Use of other public program benefits |
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Contributing factors |
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Contributing factors (cont’d) |
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a Required data elements collected and maintained within VBA administrative files on all Chapter 33 program participants
2. Use of Information
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
The information collected as part of the EDU Longitudinal Study will be used by VA to assess the long-term outcomes of Chapter 33 participants. The advantage of a longitudinal study is that it allows one to analyze changes over time, providing insights into education and employment outcomes over an extended time period. This advantage is especially important in light of the fact that individuals may take multiple years to complete their education and training goals.
The information gathered is intended to meet the policy analysis, evaluation, reporting, and planning needs of the VBA. The data will be useful in beginning to understand how the Post-9/11 GI Bill, the most comprehensive education benefit package provided by VBA to date, has been used to help Veterans (and eligible dependents) meet their education and training goals. EDU is anxious to explore the possibilities that this type of study will have on the continued improvement of the program. The annual reports resulting from the study will hopefully provide better insight on the participant characteristics and outcomes and will help EDU determine areas for improvement and evolvement.
3. Method of Collection
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting their means of collection. Also describe any consideration if using information technology to reduce burden.
It is becoming more difficult to conduct telephone surveys as people move from traditional landline telephones and are less willing to accept calls on their cell phones. There is increasing evidence that web and paper questionnaires, using accepted contact procedures (e.g., followup mailings; Dillman, et al., 2009) can achieve response rates as high (or higher) than a telephone survey.
While it has the advantage of being a very efficient data collection mode, a web questionnaire, by itself, will not provide the coverage that a paper-mail or telephone survey will provide. There are many households that do not have ready access to the web and others that will not take a survey via the web. Westat’s recent experience on the National Survey of Veterans found that only about 15 or 20 percent of Veterans were willing to complete the survey on the web (Cantor, et al., 2010). Consequently it is imperative for the EDU Longitudinal Study to combine the use of the web with another mode, such as a telephone or paper survey, to maximize response rates and minimize respondent burden. Therefore, the EDU Longitudinal Study will use a multi-modal data collection approach, combining web, mail, and telephone administration. Because participants can reside anywhere in the US (and even outside the US), in person data collection is not a cost effective method and therefore was not included in the study.
While the primary focus of the data collection approach will be to collect the data as a web survey, we will use mail surveys with those Veterans who do not complete the web survey, and we will use computer-assisted telephone interviews (CATI) with those Veterans who do not complete the web or mail survey, or indicate they would prefer to complete the survey over the telephone. Implementing a mixed-mode data collection strategy increases the number of opportunities for potential participants to complete the survey and also allows for consideration of limitations and accommodations due to disabilities. Ultimately, EDU wants to ensure the survey is readily available, easily accessible, and minimally burdensome, thereby encouraging participants to remain engaged with the study for as long as possible.
4. Avoidance of Duplication
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The measures for the study have been carefully reviewed to eliminate redundancy and duplication. Since its passage on August 1, 2009, hundreds of thousands of Veterans (and eligible dependents) have exercised the option of using the enhanced benefits provided under Chapter 33 to further their education and subsequently improve employment outcomes. There is currently no in-depth data available on Chapter 33 program participants, from the program itself or from other VBA programs, which would provide sufficient detail on the long-term outcomes of Chapter 33 participants, especially for the specific measures for this study. Furthermore, since this study involves reporting on the outcomes of program participants who have not yet been identified (i.e., Veterans who begin participation in FY2012 and FY2014), data that will be analyzed and reported on for these two cohorts is not yet available.
Each cohort will start out with participants that began participation in the Chapter 33 program. However, since this is a 20-year study, participants will eventually leave the program and EDU will have no other way of obtaining updated information on their progress, except by asking them directly. Thus, unless the agency conducts this survey, there would be no information that is already available that could be used to assess long-term outcomes. There is no issue with duplication since the majority of the data points are not currently gathered by any VBA system. Any data points that can be extracted from VBA administrative files for an entire cohort population will not be duplicated in the survey and will be measured by administrative data only.
5. Small Business Impact
If the collection of information impacts small businesses or other small entities (item 5 of OMB83-l), describe any methods used to minimize burden.
No small businesses will be included as respondents in this data collection effort; thus, the collection of information does not impact small businesses or other small entities.
6. Consequences of Not Collecting Information
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Congress has mandated the VR&E study since they want to get a better understanding of the VR&E program, its benefits, and the areas that need improvement. Congress also required that the study include three cohorts of participants who began a plan of services in fiscal years 2010, 2012, and 2014; and that VA report to them annually on specific outcomes and contributing factors of interest. In order to better understand the long-term outcomes of Veterans in general, it is critical to conduct a companion study of the Chapter 33 program, especially since some Veterans who are eligible for both programs, opt to use their Chapter 33 benefits instead of their Chapter 31 (VR&E) benefits.
If the collection is not conducted, it will be harder to understand the long-term employment and educational outcomes of Veterans. If the collection is conducted less frequently than once a year, it will be difficult to provide a yearly report that actually assesses changes in outcomes over time, and the effect the program has had on the lives of participants.
7. Special Circumstances
Explain any special circumstances that would cause and information collection to be conducted in a manner:
requiring respondents to report information to the agency often than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the university of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.
The proposed data collection is consistent with 5CFR 1320.6 and therefore involves no special circumstances. Respondents will only need to provide a response once a year and will only need to submit answers to the survey, and does not require any additional copies of any document. Respondents will not need to retain any records of their survey questions or anything else as part of this study. All information provided will be private to the extent of the law and will only be gathered for the purpose of completing a yearly report on the long-term outcomes of Chapter 33 participants.
8. Consultation Outside the Agency
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or whose who much 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.
The Department notice was published in the Federal Register (Vol. 77, No. 71) on April 12, 2012, page 22068. Public comments were received in response to this notice on the survey content from the National Association of Veterans Program Administrators, the American Council on Education, and the American Association of State Colleges and Universities. VBA also consulted with the Department of Education, Department of Justice, and the Consumer Financial Protection Bureau on the survey content. In light of the feedback received from public comments and consultation with other government agencies, the contractor for this study, Westat, also conducted an expert appraisal of the survey content, and reviewed the content of pre-existing valid and reliable surveys for Veteran populations, to further refine the survey items.
9. Reimbursement of Respondents
Explain any decision to provide any payment or gift to respondents other than reenumeration of contractors or grantees.
Study participants who complete the survey will not receive any payments or gifts.
10. Assurances of Confidentiality
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Respondents will be provided with a letter explaining the basis of this study, its importance, and their participation. The letter will also explain that participation in the study is voluntary, and that participant responses will be kept private to the extent of the law. The letter will state that the data collected will be used for research and statistical purposes, and any data reported will be in aggregate form only. More specifically, the letter will include the following assurance of confidentiality:
The information that you provide is protected by law (the Privacy Act of 1974, 5 U.S.C. 522a and section 5701 of Title 38 of the United States Code) and any data collected will not impact any current or future benefits you may apply for.
Data security and confidentiality of electronic information will be ensured through proven standardized security configurations and methods that include state-of-the art certificate services and other infrastructure features. In fact, Westat will host all study systems in its Federal Information Security Management Act (FISMA) – High enclave, which meets and exceeds the VA’s security standards.
11. Sensitive Items
Provide additional justification for any questions of a sensitive nature, as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
No questions on the survey are of a sensitive nature.
12. Estimates of Burden
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 13 of OMB Form 83-I.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.
Based VBA recent experience in fielding the VR&E Longitudinal Survey, which is similar in content to the EDU Longitudinal Survey, we estimate that it will take approximately 20 minutes for respondents to complete the annual surveys. Since the study covers a 20-year period, there are a total of 20 administrations across the full study period. The survey will be completed with 3,500 participants per cohort, for a total of 7,000 participants, for the first year of data collection which will include the initial survey for Veterans who began participation in FY2010 (i.e., Cohort I) and FY2012 (i.e., Cohort II). Those same Veterans will be contacted again to complete the annual followup survey. The annual burden hour is 2,334.
The estimated total cost to respondent is $15.00 x 2,334 burden hours = $35,010.00.
13. Estimated Annual Cost Burden to Respondents
Provide an estimate for the total annual cost burden to respondents or recordkeepers 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 include, among other items, preparations for collecting information such as purchasing computer and software; monitoring sampling, drilling and testing equipment; and 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 purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
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.
There is no annual cost burden to respondents (beyond those shown in item 12 above) or recordkeepers resulting from the collection of information.
14. Estimated Annual Burden to Federal Government
Provide estimates of annualized costs to the Federal government. Also, provide a description of the methods used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Item 12, 13, and 14 in a single table.
The estimated cost of data collection efforts associated with the burden described in item 12 has been included in the cost associated with a Firm-Fixed Price contract that was recently awarded to Westat. There is no other cost for this study. The cost for the first 3 years of data collection for the study is $425,521.98.
15. Program Changes in Burden/Cost Estimates
Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
This is a new data collection.
16. Plans/Schedules for Tabulation and Publication
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.
A report of findings will be produced on a yearly basis. This will not be published but may be available to the public once appropriate VBA offices review and approve it. There will be no costs associated with publication since the report will be available online for anyone to view if it is made publicly available. Data will be gathered every year and the report will be finalized by July 1st of every year. Table 2 below presents a schedule for conducting data collection.
Activity |
Date |
Field initial survey for FY 2010 and FY 2012 EDU Cohorts |
October 1, 2013 – December 31, 2013 |
Submit EDU Annual Report for FY 2012 |
June 1, 2013 |
Field first annual followup survey for FY 2010 and FY 2012 EDU Cohorts |
October 1, 2014 – December 31, 2014 |
Submit EDU Annual Report for FY 2013 |
June 1, 2014 |
Field second annual followup survey for FY 2010 and FY 2012 EDU Cohorts and initial survey for FY 2014 EDU Cohort |
October 1, 2015 – December 31, 2015 |
Submit EDU Annual Report for FY 2014 |
June 1, 2015 |
This report will include information on study design, sampling methodology, participant characteristics, and their responses to survey questions to measure key outcomes of interest. Some of the data will be supplemented by the VBA administrative datasets. To the extent possible, we will conduct multivariate analysis to explore the relationship between participant characteristics and key outcome variables. In the area of exploratory analysis, we will implement a full range of techniques needed for descriptive examination. We will examine frequency distributions and relationships between variables using a variety of numeric, tabular, and graphic techniques (i.e., univariate frequencies, cross tabulations, etc.).
In addition to describing the characteristics of the cohorts and examining trends related to utilization of the Chapter 33 benefits, we will use regression modeling to identify the characteristics associated with successful completion of the education or training programs being pursued as a result of using benefits. Similarly, we will similar statistical techniques to identify the characteristics associated with other long-term outcomes of interest such as employment and income.
17. Expiration Date Omission Approval
If seeking approval to not display 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 OMB approval expiration date.
18. Exceptions
Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.
There are no exceptions to Item 19 on OMB Form 83-I.
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EDU Longitudinal Study |
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Brandy Brooks |
| File Modified | 0000-00-00 |
| File Created | 2021-01-30 |