Supporting_Statement_Part_A_revised_2016_09_19

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification

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.

The Institute of Education Sciences (IES) has three fellowship training grant programs that provide funds to universities to support three types of training programs in the education sciences: 1) Predoctoral Interdisciplinary Research Training Programs, 2) Postdoctoral Research Training Program, and 3) Postdoctoral Research Training Program in Special Education. IES also supports training through non-fellowship training programs, such as the Methods Training Program and the Pathways to the Education Sciences Research Training Program. To determine the quality and effectiveness of these grant programs, IES staff have been surveying fellowship program participants annually about their satisfaction with their program and their accomplishments. Moving ahead, IES would like to adjust the timing and length of the surveys and also get information from participants in non-fellowship training programs.

Adjusting timing and length of survey. The fellowship trainings typically last 1 to 3 years, with some lasting 5 years long. The non-fellowship programs are typically much shorter, usually lasting a couple weeks to a few months. Because fellowship training participants will receive training for longer stretches of time, IES will survey them a multiple time points using questions relevant to their status within in their programs (e.g., incoming/beginning fellows versus exiting fellows). Each person will receive an entrance and an exit survey. Some predoctoral fellows will also receive a “during” training fellowship because the predoctoral training programs tend to be longer and tend to have fellows for 3 or more years, whereas the postdoctoral programs typically last fewer than two years. All fellows who complete or leave a training program will also receive a follow-up survey approximately 2 years after ending their training. Due to the short length of the non-fellowship training, IES will survey participants in these programs fewer times (e.g., only as a follow up).

To help decrease the burden on individual survey participants, IES will not track any participants for over 2 to 3 years after completion of their programs. Previously, IES tracked the fellowship participants for 5 years after completion, surveying them each year. IES will now collect data through only one follow-up survey which will occur every other year, and only fellows who completed 2 or 3 years prior to the time of the survey will be included.

Adding additional survey participants. Because of the newer training models IES supports through its grant programs (e.g., Methods Training, Pathways to the Education Sciences Research Training Program), IES would like to add additional participants to its survey protocol. The participants in these training programs would be surveyed once after concluding their training programs, and these data would inform IES’s technical assistance for the grant program.

Statutes and regulation mandating or authorizing the collection of information. The National Center for Education Research (NCER) of the Institute of Education Sciences (IES), U.S. Department of Education, is conducting this study, as authorized under Public Law 107-279, Title I, Part C, Section 131(a) and 131(b) of the Education Sciences Reform Act of 2002 and U.S. Code Title 20 Section 9543 which states:

(a) ESTABLISHMENT.—There is established in the Institute a National Center for Education Research (in this part referred to as the ‘‘Research Center’’).

(b) MISSION.—The mission of the Research Center is—

(1) to sponsor sustained research that will lead to the accumulation of knowledge and understanding of education, to—

1. ensure that all children have access to a high quality education;

2. improve student academic achievement, including through the use of educational technology;

3. close the achievement gap between high-performing and low-performing students through the improvement of teaching and learning of reading, writing, mathematics, science, and other academic subjects; and

4. improve access to, and opportunity for, postsecondary education;

(2) to support the synthesis and, as appropriate, the integration of education research;

(3) to promote quality and integrity through the use of accepted practices of scientific inquiry to obtain knowledge and understanding of the validity of education theories, practices, or conditions; and

(4) to promote scientifically valid research findings that can provide the basis for improving academic instruction and lifelong learning.

2. 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 survey information is used by IES staff to write reports that examine how the grants and their supported programs have contributed to the development of new education researchers. IES staff have used this information to improve the training programs and to provide general feedback to programs about major themes arising from the analysis. IES staff has not, and does not, provide individual programs with feedback based on responses from its fellows, nor would it do so for individual non-fellowship training programs.

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 of using information technology to reduce burden.

The survey will be conducted online so that (1) all responses are be submitted electronically, (2) participants can easily access the survey, and (3) participants can save and return to their responses. These features will decrease the amount of IES staff effort (i.e., (1)) and of participant effort (i.e., (2) and (3)).

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use of the purposes described in Item 2 above.

The survey collects data that are not available from other sources. The data, specifically quantitative and qualitative information, provides important details regarding fellows’ and other trainees’ satisfaction with the training programs and their post-training status. IES will ensure that all information that can be accurately collected from other sources or other means (e.g., from the grantees through their annual reports) will not be duplicated in the surveys.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The survey does not impact small businesses or other small entities.

6. Describe the consequences 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.

The survey is in compliance with 5 CFR1320.5. Without the survey, IES will not be in a position to determine whether its education research training grants programs were achieving their purpose and will not be able to make adjustments to improve the results of these grant programs.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• 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 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.

There are no special circumstances that would cause information collection to be conducted in any of the manners listed above.

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.

The public has had the opportunity to comment during both the 60-day and 30-day comment period notices. Also, we have received feedback from previous respondents asking if they could receive online surveys. We have been able to do this and intend to continue using the online format.

8. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts will be provided to respondents.

8. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

From a privacy standpoint, the survey cover letter cites the Privacy Act to assure respondents that the appropriate safeguards are implemented to avoid unauthorized use or disclosure of individually identifying information. The statements below will appear:

Data collection activities will be conducted in compliance with The Privacy Act of 1974.

The data have been and will continue to be stored electronically. It is retrievable by name, and the data are kept after the report is complete. The electronic files are kept in a password protected server. The security protections for the content have been identified in the SORN and PIA documents. The PIA and SORN are added assurances of confidentiality that IES is establishing protections to reasonably safeguard the respondents’ information from improper disclosure, whether intentional or unintentional.

The assurance of confidentiality for the survey of participants is as follows:

Information collected for this study come under the confidentiality and data protection requirements of the Institute of Education Sciences (The Education Sciences Reform Act of 2002, Title I, Part E, Section 183). Information that could identify an individual or institution will be separated from the survey responses submitted, kept in secured locations, and be destroyed as soon as they are no longer required. Survey responses will be used only for research purposes. The reports prepared for the study will summarize findings across individuals and institutions and will not associate responses with a specific district, school, or person. The data collection activities will be conducted in compliance with the Privacy Act of 1974.

The above statement describes the intent to keep information collected on participants’ opinions on the quality of the training programs confidential. Such information might be considered prejudicial by those running the programs or other participants if it was critical of the program. For this reason, this information will be kept confidential and reported only in aggregated data.

8. 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 this type are included in the survey.

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.

• 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.

The first series of estimates is for the participants from the predoctoral or postdoctoral trainings. Tables 1 and 2 demonstrate the different types of surveys they will get along with approximate numbers for each cohort. To estimate the cost per hour, we used the predoctoral and postdoctoral fellowship programs’ stipend and benefit caps. Predoctoral fellows receive a fellowship in the amount of $60,500 per 12 month year that covers stipend, tuition support, and fringe benefits. Using 2,088 working hours per year, this works out to a fellowship of $19.40 per hour. Postdoctoral fellows receive a fellowship in the amount of $60,500 per 12 month year that covers stipend and fringe benefits. Using 2,088 working hours per year, this works out to a fellowship of $28.74 per hour. The average annual respondents and responses will be 445 per year over three years. The average annual burden in hours for respondents will be 163 at a cost of $3510.83 per year.

Table 1: Respondents’ for Predoctoral Fellowship Surveys

Table 2: Respondents’ for Postdoctal Fellowship Surveys

Table 3: Cost Burden for Predoctoral and Postdoctoral Surveys

For the non-fellowship training program survey respondents, we are estimating using the probable number of undergraduates who will participate in our Pathways Program and professionals (e.g., research analysts, professors) who will participate in our Methods Training programs. To estimate their cost per hour, we used the national minimum wage for the undergraduates and the base salary for a GS 14.3 for the professionals because they are all likely to have doctorate degrees and experience. For these participants, we estimate an average of 135 responses per year, for an average of 34 hours of effort, for an average yearly burden of $1178.44.

Table 4: Cost Burden for Participants in Non-Fellowship Programs Surveys

Combining these two groups (fellowship participants and non-fellowship participants), we have a total of 580 responses per year on average, the total average number of hours is 197, and the total cost is $4689.27.

The following PRA Burden statement will appear on each online survey:

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless such collection displays a valid OMB control number.  The valid OMB control number for this information collection is 1850-0873.  Public reporting burden for this collection of information is estimated to average 20 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.  The obligation to respond to this collection is voluntary.  If you have comments or concerns regarding the status of your individual submission of this form, application or survey, then please contact Phill Gagné directly at 202-245-7139.

9. 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.)

There are no capital costs, no start-up costs, and no costs for operation and maintenance and purchase of services.

8. 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 survey, data analysis, and report writing will be handled by IES education research analysts. Because the survey is conducted online, the analysis is done in house, and the report will be published electronically, there are no equipment, printing, and overhead costs. The annual cost to the Federal government is estimated to be about $26,675, calculated as 550 total personnel hours at an average rate across the personnel involved of $48.50/hr.

8. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

The number of distinct surveys has increased due to the addition of surveys for non-fellowship trainees (e.g., those in the Pathways Training programs) and to the proposed redesign of the surveys’ timing for the predoctoral and postdoctoral fellows (i.e., an entrance, exit, and follow-up survey). The overall burden for a given respondent is anticipated to be lower, because: (1) The survey will be online; (2) Respondents will receive targeted questions based on where they are in their programs (e.g., have not completed the program, finished 2 years ago, etc.); and (3) Fellows will be tracked for only 2 years after completing their fellowships, rather than the previous 5 years. Given these adjustments, the overall burden on the participants has reduced by 21 hours – from 218 per year previously to 197.

8. 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.

For all surveys, IES staff will send links to participants via email at the beginning of the month during which data collection will begin. The participants will have 6 weeks to complete the survey. IES staff will take approximately 6 to 8 weeks to process the results and another 8 weeks to prepare a report about the results. The analyses will make use of tabulations. No complex analytical techniques will be used. Depending on whether the results will be posted online, additional time for review of the report may be required.

For the predoctoral and postdoctoral fellows:

Survey	Begins	Ends	Data Analysis	Report
Entrance	September	October	November - December	February
During Training	January	March	April - May	July
Exit	June	August	September - October	December
Follow-up	June	August	September - October	December

For the non-fellowship training surveys, the schedule will remain the same, i.e., the approximate number of weeks for data collection, analysis, etc. However, the timing of the survey will be contingent on the timing of the training programs, but IES predicts that most of the surveys will be sent in June, following the Exit and Follow-up schedule noted in the table above.

8. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Approval is not being sought to not display the expiration date for OMB approval of the information collection.

8. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

No exceptions are being sought for this work.

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