Justification

DOCUMENTATION FOR THE GENERIC CLEARANCE

OF CUSTOMER SERVICE SATISFACTION COLLECTIONS

TITLE OF INFORMATION COLLECTION:

Gainful Employment Focus Groups

[ ] SURVEY [X ] FOCUS GROUP [ ] SOFTWARE USABILITY TESTING

DESCRIPTION OF THIS SPECIFIC COLLECTION

Specify all relevant information, including

1. intended purpose,

2. need for the collection,

3. planned use of the data,

4. date(s) and location(s),

5. collection procedures,

6. number of focus groups, surveys, usability testing sessions

7. description of respondents/participants.

1. Intended purpose, need for collection, and planned use of the data

Westat is working with the Department of Education to conduct two focus groups on activities related to the Gainful Employment (GE) regulations (34 CFR 668.6(b)) that take effect in 2017. The Department has established measures to determine whether certain programs at for-profit and vocational postsecondary education institutions are providing reliable consumer information on specific types of data, and to hold them accountable for these measures. These data include, but are not limited to: program information, cost, student debt (e.g., loan repayment rate, median loan debt), program completion (i.e., graduation and withdrawal rates), and program employment (e.g., job placement rate, primary occupation by name and Standard Occupational Classification code).

The stated purpose of the regulations is to address growing concerns that educational programs required by statute to provide training that prepares students for gainful employment in a recognized occupation (GE programs), are instead leaving students with unaffordable levels of loan debt in relation to their earnings, or leading to default. GE programs include nearly all educational programs at for-profit institutions of higher education, as well as non-degree programs at private nonprofit institutions and public institutions such as community colleges.

Under the regulations that were issued in October 2014, postsecondary institutions with GE programs are required to disclose to current and prospective students information about their institution’s career and training certificate programs through a disclosure template developed by the Department. The regulations identify a series of possible data elements to be collected through a revised disclosure template beginning in 2017. The Department must decide which of the possible data elements from the regulations should be included in the 2017 GE template. Westat will conduct two focus groups to inform this decision.

The purpose of the focus group of students who are currently enrolled in GE programs is to: (1) discuss the purpose and meaning of the data elements and determine if and how they might use them, and (2) prioritize the elements based on their opinions about which data elements would be most useful and more likely to be used.

The purpose of the focus group with institutional representatives is to: (1) determine the burden associated with collecting and reporting on the new elements, (2) prioritize the data elements based on their understanding of how students would use them, and (3) review and discuss the student warning language institutions will be required to provide if their GE program could become ineligible based on its final debt to earnings rates measure for the next award year as required by the GE regulations.¹

These data are needed in order for the Department to understand how students and those who work closely with them prioritize the data elements and the utility of the various data elements. These data will be used to aid in decision-making regarding which data elements will be collected on the 2017 GE template.

2. Date and location, collection procedures, and description of participants

The Department has contracted with Westat to conduct a total of two (2) focus groups at our offices in Rockville, MD. Our state of the art focus group facilities allow for members from the Department to observe from behind two-way mirrors and for recording of participants. All focus groups will be conducted by a trained moderator. The focus groups will be held in early December 2015.

The first focus group will test the possible data elements with students who are enrolled in GE programs. The second focus groups will test the possible data elements with representatives of institutions in the DC metropolitan area that offer these programs. Each focus group will have nine (9) participants.

Under Westat’s direction and supervision, Shugoll Research in Bethesda will recruit students who meet the following criteria, which we will provide to them:

• Focus Group #1: Students (ages 19-35) currently enrolled part time or full time in a DC metropolitan area 2-year community college or proprietary school, which has a 1- or 2-year vocational/career program leading to a certificate. (Students enrolled in programs that lead to associate’s or bachelor’s degrees will be excluded from the focus group.) We plan to recruit for a heterogeneous group of students by race/ethnicity and gender, with a focus on those from low-moderate income families.

Westat will recruit institutional representatives who meet the following criteria:

• Focus Group #2: Institutional representatives, primarily IPEDS key holders working in institutional research or student financial aid offices, currently employed in a DC metropolitan area proprietary and community colleges offering 1- to 2-year certificates in career or training programs. Institutional representatives who work at postsecondary institutions that also offer a bachelor’s degree or above will be excluded from these focus groups.

Each focus group will use three separate ranking exercises for students and representatives to complete for the purpose of prioritizing the data elements.

Prior to participating in the focus groups, participants will be informed that the discussion will be audiotaped and they will be asked to sign an informed consent form agreeing to participate in the discussion and to being audio recorded. Focus groups will be recorded, transcribed, and analyzed. The report will analyze data in the aggregate and not permit the identification of individuals or the institutions with which they are associated.

Each focus group will be completed one time only.

Attachments include the two (2) focus group screeners/recruitment scripts (Attachment A-Student Screener; Attachment B-Institutional Representative Screener) and two (2) moderator guides (Attachment C-Student Moderator Guide; Attachment D-Institutional Representative Moderator Guide). Also attached are the six ranking exercises (three per group) to be completed by participants during each focus group (Attachments E-G for students; Attachments H-J for institutional representatives).

AMOUNT OF ANY PROPOSED STIPEND OR INCENTIVE

Each of the two focus groups (one for students enrolled in gainful enrollment programs, and one for institutional representatives of colleges offering gainful enrollment programs) will offer a $75.00 incentive per participant who shows up to participate in the focus group. We will recruit 12 in each group to ensure that 9 will show up to participate. Each person who shows up will receive an incentive. We are offering an incentive to adult students since they often do not show up for focus groups due to busy work and school schedules. Institutional representatives also are being offered an incentive to encourage their participation in the focus group, which will be held in the evening after working a full day.

BURDEN HOUR COMPUTATION (Number of responses (X) estimated response or participation time in minutes (/60) = annual burden hours):

Category of Respondent	No. of Possible Recruits Screened	Time to Answer Screener Questions	Respondents	Participation Time in the Focus Group	Burden
Students enrolled in colleges offering gainful employment (GE) programs	36	10 minutes	9	120 minutes	24 hours
Institutional representatives of colleges offering gainful employment (GE) programs	20	10 minutes	9	120 minutes	21hours
Totals	56 possible recruits		18 respondents		45hours

BURDEN COST COMPUTATION

Category of Respondent	No. of Respondents	Hourly Rate	Response Time	Total
Students enrolled in colleges offering gainful employment (GE) programs	9	$37.5	2 hours	$675
Institutional representatives of colleges offering gainful employment (GE) programs	9	$37.5	2 hours	$675
Totals	18 respondents			$1350

STATISTICAL INFORMATION

No statistical methods are being used to recruit focus group participants or analyze the data.

REQUESTED APPROVAL DATE:

NAME OF CONTACT PERSON: Amy E. Wilson

TELEPHONE NUMBER: 202-502-7689

MAILING LOCATION: 1990 K St., 8th floor, Washington, DC 20006-8540

ED DEPARTMENT, OFFICE: Policy, Planning, and Innovation

1 The debt-to-earnings rates are calculated by the Department for the next award year. The institution must provide warnings to both current and prospective students.

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