PYFP Supporting Statement A 09FEB2017

SUPPORTING STATEMENT FOR THE

EVALUATION OF THE PRESIDENTIAL YOUTH FITNESS PROGRAM

PART A

Submitted by:

Sarah M. Lee, PhD

School Health Branch

Division of Population Health

National Center for Chronic Disease Prevention and Health Promotion

4770 Buford Hwy, NE Mail stop K78

Atlanta, GA 30341
770-488-6162 (voice); 770-488-5964 (fax)

E-mail: [email protected]

Centers for Disease Control and Prevention
Department of Health and Human Services

09/01/2016

Contents

A. Justification 1

A.1 Circumstances Making the Collection of Information Necessary 1

A.2 Purpose and Use of Information Collection 13

A.3 Use of Improved Information Technology and Burden Reduction 14

A.4 Efforts to Identify Duplication and Use of Similar Information 14

A.5 Impact on Small Businesses or other Small Entities 14

A.6 Consequences of Collecting the Information Less Frequently 14

A.7 Special Circumstances Relating to the Guidelines of 5 CFR 1320.5 15

A.8 Comments in Response to the Federal Register Notice & Efforts to Consult Outside the Agency 15

A.9 Explanation of Any Payment or Gift to Respondents 16

A.10 Protection of the Privacy and Confidentiality of Information Provided by of Respondents 16

A.11 Institutional Review Board and Justification for Sensitive Questions 18

A.12 Estimates of Annualized Burden Hours and Costs 18

A.13 Estimates of other Total Annual Cost Burden to Respondents or Record Keepers 21

A.14 Annualized Cost to the Government 21

A.15 Explanation for Program Changes or Adjustments 22

A.16 Plans for Tabulation and Publication and Project Time Schedule 22

A.17 Reason(s) Display of OMB Expiration Date is Inappropriate 25

A.18 Exceptions to Certification for Paperwork Reduction Act Submissions 25

List of Attachments

General Attachments

Attachment 1: Authorizing Legislation

Attachment 2a: 60-day Federal Register Notice

Attachment 2b: 60-day Federal Register Notice Response to Comments

Attachment 3a: PYFP Round of Funding Timeline

Attachment 3b: PYFP Funding FAQ

Attachment 4: Summary of Data Collection Activities by School Type

School Recruitment

Attachment 5a: Superintendent School Recruitment Letter (PYFP Schools)

Attachment 5b: Superintendent School Recruitment Letter (non-PYFP Schools)

Attachment 6a: Principal School Recruitment Letter (PYFP Schools)

Attachment 6b: Principal School Recruitment Letter (non-PYFP Schools)

Attachment 7a: PYFP Evaluation Overview and Acknowledgement Form (PYFP Schools)

Attachment 7b: PYFP Evaluation Overview and Acknowledgement Form (non-PYFP Schools)

Attachment 8: Presidential Youth Fitness Program Evaluation Q & A

Attachment 9a: Superintendent Recruitment Call Script (PYFP Schools)

Attachment 9b: Superintendent Recruitment Call Script (non-PYFP Schools)

Attachment 10a: Principal Recruitment Call Script (PYFP Schools)

Attachment 10b: Principal Recruitment Call Script (non-PYFP Schools)

Attachment 11a: School Liaison Recruitment Letter (PYFP Schools)

Attachment 11b: School Liaison Recruitment Letter (non-PYFP Schools)

Attachment 12a: School Liaison Recruitment Call Script (PYFP Schools)

Attachment 12b: School Liaison Recruitment Call Script (non-PYFP Schools)

Respondent Recruitment

Attachment 13a: Parent Letter – Passive Consent Survey and Fitness Assessment

(PYFP Schools)

Attachment 13b: Parent Letter – Passive Consent Survey and Fitness Assessment

(non-PYFP Schools)

Attachment 14: Focus Group Parent Consent and Interest Form (PYFP Schools)

Attachment 15: Parent Accelerometer Consent Form

Attachment 16a: Parent Letter – Active Consent Survey and Fitness Assessment

(PYFP Schools)

Attachment 16b: Parent Letter – Active Consent Survey and Fitness Assessment

(non-PYFP Schools)

Attachment 17: Physical Education (PE) Teacher Invitation to Participate in PYFP Evaluation Activities

Attachment 18: School Administrator Invitation to Participate in Survey

Surveys

Attachment 19a: PE Teacher Survey (PYFP Schools)

Attachment 19b: PE Teacher Survey (non-PYFP Schools)

Attachment 20a: Student Survey (PYFP Schools)

Attachment 20b: Student Survey (non-PYFP Schools)

Attachment 21a: School Administrator Survey (PYFP Schools)

Attachment 21b: School Administrator Survey (non-PYFP Schools)

Attachment 22: PYFP Cost Worksheet

Attachment 23: PYFP Time Use Worksheet

Focus Groups

Attachment 24: Parent Focus Group Moderator Guide

Attachment 25: PE Teacher Focus Group Moderator Guide

Attachment 26: Student Focus Group Moderator Guide

FitnessGram® & Accelerometry

Attachment 27: FitnessGram® Data Collection Protocol

Attachment 28: FitnessGram® Data Collection Form

Attachment 29: Pacer Test Individual Score Sheet

Attachment 30: Accelerometry Data Collection Protocol

Attachment 31: Accelerometry Log

Attachment 32: Accelerometry Data Collection - Instructions for PE Teachers

Attachment 33: Accelerometry Belt Instructions

Attachment 34: Accelerometry School Liaison Data Collection Checklist

Consents & Assents

Attachment 35: ICF Institutional Review Board Approval Memorandum

Attachment 36: PE Teacher Survey Consent

Attachment 37: School Administrator Survey Consent – Online Survey

Attachment 38: PE Teacher Focus Group Consent Form

Attachment 39: Parent Focus Group Consent Form

Attachment 40: Student Accelerometry Assent

Attachment 41: Student Focus Group Assent

Design

Attachment 42: PYFP Evaluation Question and Instrument Crosswalk

Attachment 43: Summary of the Literature Informing Power Analyses

• The goal of this evaluation is to assess the impact of the Presidential Youth Fitness Program (PYFP) on PE teacher, student and school-level outcomes as well as barriers and facilitators to program implementation.

• Results will be used to (1) inform stakeholders about whether PE teacher, student and school-level outcomes differ among schools implementing the PYFP versus those offering a traditional physical education course and (2) provide information that will be used for program improvement.

• The design approach is a mixed-methods, two-group, quasi-experimental design, focusing on select middle schools participating in Round 2 and Round 3 of PYFP funding and matched comparison (non-PYFP) schools.

• Data collection activities will occur with those teaching 6^th grade PE, students enrolled in 6^th grade PE, parents of students in 6^th grade PE and school administrators.

• Data will be analyzed to obtain descriptive statistics and logistic regression will be used to examine change over time and impact of the PYFP compared with the traditional PE course.

This statement supports a request to obtain approval for all data collection activities associated with the Presidential Youth Fitness Program (PYFP) Evaluation. The PYFP is a program available to elementary, middle and high school physical education (PE) teachers and is intended to compliment the traditional PE program and support PE teachers in laying the foundation for students to lead an active life. The three key components of the program are (1) fitness assessments, (2) professional development and teacher training and (3) student recognition. The mission of the PFYP is to provide a model for fitness education that supports teachers and empowers students to adopt an active lifestyle. Participation in the program is voluntary, and upon being accepted into the PYFP after applications are reviewed annually, schools receive a variety of resources, including professional development training, awards for student recognition, and access to FitnessGram® fitness assessment software. The PYFP has been developed through a partnership with the President’s Council for Fitness, Sports and Nutrition; the Centers for Disease Control and Prevention; SHAPE America (the Society for Health and Physical Education Educators); the Cooper Institute; and the National Foundation on Fitness, Sports and Nutrition.

For the purposes of this ICR, we are using the term evaluation to refer to this project although the design is not a true pre-test/post-test. However, our design does include an implementation group (PYFP schools) and control (non-PYFP schools). We have refrained from using the term “assessment” to refer to this project given that in educational settings the term assessment is often associated with testing. In addition, the term “assessment” is used when referring to one of the student outcome measures, FitnessGram® fitness assessment. Referring to the overall project and an outcome measure as an “assessment” could lead to confusion when describing this project. For clarity and acceptability, this project is referred to as the PYFP Evaluation.

1. Justification

A.1 Circumstances Making the Collection of Information Necessary

This is a new Information Collection Request (ICR) to support all data collection activities associated with the Presidential Youth Fitness Program Evaluation, a program designed to supplement the traditional PE course and support physical education (PE) teachers in laying the foundation for students to lead an active life. The evaluation will be conducted in approximately 11 middle schools¹ implementing the PYFP and 11 match comparison schools. ICF (a public health consulting company) will lead the evaluation which will allow program stakeholders to assess student, PE teacher and school-level outcomes among schools that implement the PYFP against those that offer a traditional PE course. The evaluation will also focus on process evaluation to help stakeholders understand implementation and inform program improvement. Data will be collected during the spring and fall semesters of 2017. Data collection activities will include fitness assessments, surveys (PE teachers, administrator and students), accelerometry and focus groups (PE teachers, students and parents). This ICR seeks approval from the Office of Management and Budget for the last two years of the three year evaluation study period.

Starting in 2013, the Presidential Youth Fitness Program began its first round of funding to elementary, middle and high schools whose PE teachers applied to the program. A second round of funding began in 2014 and a third in 2015 (Attachment 3a PYFP Round of Funding Timeline). Each participating school receives support to implement the PYFP for three years. The resources provided to PE teachers include: professional development training, awards for student recognition of fitness achievements, access to a professional learning community and access to FitnessGram® fitness assessment software. For the schools that apply to the PYFP grant program and receive supplemental program resources to enhance implementation of the program, the requirements include: 1) IT manager and PE teacher participation in the FitnessGram® software training, 2) PE teacher participation in PYFP professional development training, 3) conducting FitnessGram® assessments according to the training, 4) recognizing student achievement in fitness and physical activity (PA), 5) confirming continued participation in the program at the end of Years 1 and 2 and 6) participating in evaluation activities, including the submission of required data on an annual basis (Attachment 3b PYFP Funding FAQ). Schools with only grades K-2 or K-3 were excluded from funding and any school that did not have a certified PE teacher.

The PYFP evaluation includes four common data collection activities in PYFP and non-PYFP schools: 1) PE teacher surveys, 2) School Administrator Surveys, 3) Student Surveys and 4) Student fitness assessments using FitnessGram’s ® pacer and body composition assessments. In a subset of all schools there will also be measures of student PA using accelerometers. Additional data collection activities will occur in PYFP schools to assess implementation. This will include: 1) a cost/time questionnaire to be completed by PE teachers and/or administrators and 2) focus groups with PE teachers, students and parents. Evaluation data will be used for the purposes of program improvement. Data from this evaluation also will be used to examine whether the PYFP is leading to improved teacher, student and school-level outcomes in the short-term, all of which are anticipated to positively impact student PA and health in the long-term. The rationale for the PYFP evaluation is described below.

A.1.a Background

A.1.a.1 Public Health Implications of Obesity and Inadequate Physical Activity and Fitness among Adolescents

Child and adolescent obesity is currently a major public health concern. In 2014 the prevalence of obesity in adolescents aged 12-19 reached 21% .¹ It is well documented that obesity and a lack of PA among children and adolescents increases risk factors for potential health issues during childhood and into adulthood.^2,3 Overweight adolescents are more likely to become overweight adults and obesity is a known risk factor for a wide range of diseases, including cardiovascular disease, type 2 diabetes and certain cancers.^4,5 In addition to increased risk for physical health problems, obese youth may be at greater risk for experiencing social or psychological problems such as stigmatization and low self-esteem. ^6,7

Research has shown that youth who engage in regular PA are at lower risk for overweight and obesity compared with those who do not engage in regular PA.⁸ In addition, higher levels of cardio-respiratory fitness have been associated with lower body mass index in youth and greater health benefits.^9-11 Therefore, strategies to increase opportunities for youth to engage in PA and improve cardiorespiratory fitness are important for obesity prevention and overall health both in childhood and later in life.

A.1.a.2 Role of Schools in Promoting Physical Activity

Because school-aged children spend more than half of their waking hours in school and engage in 20%–30% of their total PA at school, schools are ideal settings for reaching a diverse cross-section of children with interventions to increase PA, including children experiencing health disparities.¹² This is particularly important in middle school, where research shows levels of PA decrease when compared with younger students.^13-15 For this reason, school-based programs focused on empowering middle school students to be physical active and maintain or improve fitness are particularly important for promoting health and healthy behaviors in the short- and long-term.

A.1.a.3 An Expanded Federal Role in the Prevention of Obesity and Inadequate Physical Activity and Fitness among Adolescents

A number of federal grants and programs have been initiated to combat and prevent adolescent obesity. These efforts focus on increasing PA, promoting healthy eating habits and creating greater opportunity for youth to be physically active during and outside of the school day. Examples of these programs include Step It Up!; The Surgeon General’s Call to Action to Promote Walking and Walkable Communities; the Let’s Move Campaign; State Public Health Actions to Prevent and Control Diabetes, Heart Disease, Obesity and Associated Risk Factors and Promote School Health (1305); and the Presidential Youth Fitness Program (PYFP).

Data from this evaluation will help inform program improvement for the PYFP and assess the quality of PE and overall student fitness in PYFP and non-PYFP schools. These data will also demonstrate the impact of a Federal Program in promoting increased PA and addressing obesity prevention.

The specific aims of this evaluation and related evaluation questions are as follows:

PROCESS EVALUATION

1. Identify barriers and facilitators of PYFP implementation for program improvement

1. What are the barriers and facilitators to PYFP implementation?

2. What are the costs associated with PYFP implementation?

3. What supports are present in the school for PA and PE programming?

4. What are PE teachers’ continued professional development needs?

2. Determine strategies used to implement PYFP, increase support for the program

and integrate more fitness education into the curriculum

5. What strategies do schools use to implement the PYFP (e.g., increasing support for PYFP, integrating fitness education, communicating about PYFP and fitness results)?

6. What items were provided to students when they were recognized for their fitness achievements?

7. What PYFP resources did PE teachers receive, and how were they used by teachers?

OUTCOME EVALUATION

3. Examine how PYFP impacts student fitness and PA

8. How does the PYFP impact student fitness and health knowledge?

9. How does the PYFP impact student attitudes toward PA or motivation to be physically active?

10. How does the PYFP impact student PA?

11. How does the PYFP impact student fitness?

12. What is the impact of recognizing students’ fitness achievements, and what is the impact of recognition awards?

4. Determine changes made as a result of the PYFP

13. To what extent does implementation of the PYFP lead to improved PE and PA policies, practices and/or environments?

14. To what extent does PYFP lead to increases in parent PE/PA awareness?

15. Has implementation of the PYFP led to integration of fitness education in PE?

16. Has implementation of the PYFP led to increased use of fitness assessment tools?

17. Has implementation of the PYFP led to improved practices for fitness testing?

A.1.b Overview of the Data Collection System

The PYFP evaluation will be implemented in select middle schools participating in PYFP funding Rounds 2 (PYFP funded from 2014-2017) and 3 (PYFP funded from 2015-2018) and matched comparison schools (non-PYFP). Exhibit A.1-1 provides the inclusion, exclusion and match comparison criteria for school selection.

Exhibit A.1-1. Inclusion, Exclusion and Matching School Selection Criteria

School Selection Criteria		PYFP Schools	Non-PYFP Schools
Inclusion Criteria
Round 2 and Round 3 PYFP funded schools		●
Schools with a sixth grade		●	●
Percentage of students with free or reduced lunch eligibility (50% or higher)		●	●
High PYFP implementation (course completion, fitness assessment, student recognition and communication with parents and administrators)		●
Exclusion Criteria		PYFP Schools	Non-PYFP Schools
Charter schools		●	●
Elementary schools (grades K–8)		●	●
Past or current participation in PYFP			●
Matching Criteria: PYFP Schools Versus Non-PYFP Schools		PYFP Schools	Non-PYFP Schools
Geographic area (urban or rural classification) School enrollment/school size PE curricula Percentage of students eligible for free or reduced lunch	PE requirements/policies Minutes of PE per week PE teacher to student ratio Racial/ethnic group percentages

All PYFP evaluation data collection activities will be led by ICF. ICF will work with colleagues and noted subject matter experts, Dr. James Sallis and Kelli Cain from the University of California – San Diego, to conduct the accelerometry portion of the evaluation. In addition, the evaluation team will recruit one individual from each participating school/school district to serve as a school liaison, helping to coordinate respondent recruitment and data collection activities.

The PYFP evaluation includes data collection activities that will occur in all schools and some data collection activities will occur only in a subset of schools (Attachment 4 Summary of Data Collection Activities by School Type). All schools will participate in student surveys, PE teacher surveys and administrator surveys with different versions for PYFP and non-PYFP schools. Fitness assessment data will be collected at all schools for students enrolled in 6^th grade PE at the beginning and end of the PE semester. PYFP schools will be asked to complete beginning of semester assessments on their own using a standardized data collection form and trained ICF staff will collect end of semester assessments. For non-PYFP schools, trained ICF staff will conduct both beginning and end of semester assessments.

A subset of all PYFP and non-PYFP schools will participate in accelerometry data collection. Up to seven PYFP and seven non-PYFP schools will participate in the accelerometry substudy. All schools will be asked to participate in the accelerometry sub-study until reaching the total number of school needed. Within each sub-study school, we will randomly select 10 students per 6^th grade PE class from those who have returned parental consent forms. Students will wear accelerometers for a full 7-day week at the beginning and end of the PE semester.

A subset of six PYFP schools will be included in qualitative data collection, three Round 2 schools (Wave 1) and three Round 3 schools (Wave 2). This will involve focus groups with PE teachers, students and parents. Schools will be randomly selected for focus group participation. School liaisons will assist with recruitment and scheduling. Each focus group (parent, student and PE teacher) will include up to ten participants.

The evaluation design is cross-sectional with the exception of student accelerometry and fitness assessments conducted at the beginning and end of the PE semester. Six Round 2 PYFP and six match comparison schools will participate in data collection during the spring 2017 semester (Wave 1); five Round 3 schools and five match comparisons will participate in data collection during fall 2017 semester (Wave 2). PE teacher and school administrator surveys will be hosted online by SurveyMonkey® and hard copy surveys will be administered to 6^th grade students (Attachments 19a & 19b PE Teacher Surveys, Attachments 20a & 20b Student Surveys, and Attachments 21a & 21b School Administrator Surveys). Neither the web-based survey nor the paper surveys will ask for- or contain identifiable information. The evaluation team will also assess cost and time needed to implement the PYFP program with cost and time use worksheets. Administrators will be asked to complete the cost worksheet and PE teachers will be asked to complete the time use worksheet.

School Recruitment. The evaluation team will first seek permission from the district superintendent and principal of each school (PYFP and non-PYFP) identified for recruitment. Superintendents will be contacted first and sent a recruitment packet (Attachments 5a & 5b Superintendent School Recruitment Letters, Attachments 7a & 7b Overview and Acknowledgement Forms and Attachment 8 Presidential Youth Fitness Program Evaluation Q&A) along with materials to forward to the school principal if superintendent permission is given (Attachments 6a & 6b Principal School Recruitment Letters). Superintendents will document their acknowledgement and permission by signing and returning the Overview and Acknowledgement Form to ICF. Superintendents will also be asked to forward the envelope from their packet addressed to the principal. The principal envelope will include a school recruitment letter as well as the Overview and Acknowledgement Form and the Q&A. ICF will track receipt of letters via FedEx and follow-up calls will be placed to district superintendents and principals approximately one week after letters are received. Principals will also be asked to sign and return an overview and acknowledgement form to ICF. Wave 1 Schools (Spring 2017 semester) will be recruited in November/December 2016 and Wave 2 Schools will be recruited in May/June 2017. Exhibit A.1-2 below provides an overview of the communication and timing related to school recruitment.

Exhibit A.1-2. School Recruitment, Mode of Communication and Timing

Communication Mode	Timeframe	Purpose of Contact
Superintendents
Letter and District Recruitment Packet (Attachments 5a, 5b, 7a & 7b)	Day 1	Introduce the PYFP evaluation to superintendents Provide superintendents with an overview of data collection activities Obtain superintendent permission for school involvement
Follow-up call (Attachments 9a & 9b)	Day 7	Confirm packet was received Address any questions or concerns Ask for school liaison recommendations Obtain permission for school involvement and remind superintendents to forward information to the school’s principal
Principal
Letter and school recruitment packet (Attachments 6a, 6b, 7a & 7b)	Day 2- Day 13	Introduce the PYFP evaluation to principals Provide principals with an overview of data collection activities Obtain principal permission for school involvement
Follow-up call (Attachments 10a & 10b)	Day 14	Confirm packet was received Address any questions or concerns Obtain permission for school involvement Review superintendent recommendations for school liaison and ask for additional suggestions

School Liaison Recruitment. During the school recruitment phase, superintendents and principals will be asked to provide recommendations of staff who could serve the role of school liaison. The evaluation team will send an email to these individuals and follow-up via telephone to gauge interest and ability to support respondent recruitment and data collection (Attachments 11a & 11b School Liaison Recruitment Letters, Attachments 12a & 12b School Liaison Recruitment Call Script). Once the evaluation team has selected a liaison for each school, a follow-up email will be sent and individuals will be asked to confirm acceptance. After all liaisons are confirmed a web-based orientation will be held. Exhibit A.1-3 below provides an overview of the communication and timing related to school liaison recruitment. School liaisons for Wave 1 (Spring 2017) will be recruited in November/December of 2016. School liaisons for Wave 2 (Fall 2017) will be recruited in May/June 2017.

Exhibit A.1-3. School Liaison Recruitment, Mode of Communication and Timing

Communication Mode	Timeframe	Purpose of Contact
Superintendent & Principals
Superintendent follow-up school recruitment call	Day 7	Obtain recommendations for staff who could serve the role of school liaison
Principal follow-up school recruitment call	Day 14
Potential School Liaisons
Letter/Email (Attachments 11a & 11b)	Day 15	Notify potential liaisons that they have been recommended by superintendents/principals to serve role Introduce the PYFP evaluation and responsibilities of school liaison
Follow-up call (Attachments 12a & 12b)	Day 22	Confirm packet was received Address any questions or concerns Gauge interest and ability to serve as the school liaison
Follow-up email/call	Day 25	Notify all individuals recruited of school liaison appointment
Provide PYFP Evaluation Overview Training	Day 32	Orient liaison to the goals of the PYFP evaluation as well as all data collection activities Review the role of liaisons

Respondent Recruitment. The PYFP evaluation team will rely on the school liaisons for on-the-ground respondent recruitment. Prior to the start of data collection, school liaisons will be trained on respondent recruitment by the evaluation team and will be provided with the necessary human subjects’ research training. Next liaisons will be sent packages with all student and parent recruitment materials and a call will be scheduled with the evaluation team to ensure liaisons: 1) received all necessary materials, 2) understand when and how materials should be distributed and 3) have an opportunity to role play the school recruitment script to be given in all 6^th grade PE classes. School liaisons will distribute student/parent recruitment packets during 6^th grade PE classes and provide a brief overview of the evaluation, data collection activities and discuss the due date for returning consent forms to their PE teacher. The evaluation team will seek passive consent for student participation in fitness assessments and surveys (Attachments 13a & 13b Parent Letters – Passive Consent Survey and Fitness Assessment) and active consent for accelerometry and focus group participation (Attachment 14 Focus Group Parent Consent and Interest Form, Attachment 15 Parent Accelerometer Consent Form). If a school does not allow passive consent for student participation in fitness assessments and surveys, the evaluation team will pursue active consent and school liaisons will distribute active consent letters to be sent home to parents (Attachment 16a & 16b Parent Letters – Active Consent Survey and Fitness Assessment). Exhibit A.1-4 below provides an overview of the communication and timing related to student and parent respondent recruitment.

For PE teachers and administrators, school liaisons will be asked to obtain their names and email addresses for survey administration. Letters will be sent to notify PE teachers and administrators about evaluation data collection activities (Attachment 17 PE Teacher Invitation to Participate in PYFP Evaluation Activities, Attachment 18 School Administrator Invitation to Participate in Survey). ICF will send surveys to respondents via email.

Exhibit A.1-4 Respondent Recruitment, Mode of Communication and Timing

Communication Mode	Timeframe	Purpose of Contact
School Liaisons
Recruitment and data collection training led by ICF	3 weeks before start of semester	Review recruitment timelines Discuss recruitment
Recruitment documents package follow-up call with ICF	2 weeks before the start of semester	Review contents of recruitment package Answer any questions
Students/Parents
PYFP evaluation presentation – 6th grade PE classes given by school liaison	1st week of the semester	Describe the PFYP evaluation Describe student and parent data collection activities Distribute student and parent recruitment packets including consent forms Request forms are returned within 7 days
School liaison in-person check-in with PE teachers	2nd week of the semester	Collect consent forms
ICF follow-up with parents	4th week of the semester	Follow-up with parents who did not provide consent for child’s participation in accelerometry or fitness assessments to see if they give permission to participate in the student survey

A.1.c

Items of Information to be Collected

Surveys. Surveys will be administered to PE teachers, students and school administrators in PYFP and non-PYFP schools. Different survey instruments will be used for each school type, as the PYFP surveys will include questions related to the program. Exhibit A.1-5 provides an overview of the survey instruments, respondent types, sampling frames and survey domains.

Exhibit A.1-5. Respondent Types, Surveys, Sampling Frames and Survey Domains

Survey Instrument	Respondents Type	Sampling Frame	Survey Domains
PE Teacher Survey (PYFP) (Attachments 19a)	PE Teachers	6th grade PE teachers in select PYFP and Non-PYFP schools	PE teaching practices School supports for PE and PA Fitness assessments and fitness education Student recognition Professional development Resources for the PYFP (PYFP only) Teaching practices prior to program (PYFP only) Program implementation (PYFP only) Demographics
PE Teacher Survey (Non-PYFP) (Attachment 19b)
Student Survey (PYFP) (Attachment 20a)	Students	Students enrolled in 6th grade PE: PYFP and Non-PYFP	PE frequency School support for PE and PA Knowledge and PE attitudes PA attitudes and behavior Fitness assessments Student recognition and fitness goals Demographics
Student Survey (Non-PYFP) (Attachment 20b)
School Administrator Survey (PYFP Schools) (Attachment 21a)	School Administrators	Lead school administrator at PYFP and Non-PYFP schools	PE frequency and requirements School PE and PA policies and practices School resources supports for PE and PA Communication PYFP implementation (PFYP only) Demographics
School Administrator Survey (Non-PYFP Schools) (Attachment 21b)
School Cost Worksheet (Attachment 22)	School Administrators	Administrators from PYFP Schools	Cost associated with professional development, student recognition, fitness education and the traditional PE course
School Time Use Worksheet (Attachment 23)	PE Teachers	PE Teachers from PYFP Schools	Time associated with implementation of the PYFP and the traditional PE course

Focus groups. Focus groups will be conducted in PYFP schools with PE teachers, students and parents. Although there is some overlap in the domains covered through surveys and focus groups (e.g., child PA attitudes and behavior; professional development; PYFP implementation; student recognition; fitness assessments; school supports for PA), qualitative data collection will be conducted to gain more information and insight about these topics in order to learn about barriers and facilitators to implementation and effective strategies for implementation of the PYFP. Focus groups with students and parents will also allow the evaluation team to examine parent and student perceptions of the PYFP and PE. Exhibit A.1.6 provides an overview of the focus group instruments, respondent types, sampling frames and focus group domains.

Exhibit A.1-6. Respondent Types, Surveys, Sampling Frames and Focus Group Domains

Focus Group Instrument	Respondents Type	Sampling Frame	Focus Group Domains
Parent Focus Group Moderator Guide (Attachment 24)	Parents of 6th graders	Parents of students enrolled in 6th grade PE at PYFP schools	Awareness of the PYFP Awareness of fitness assessments Communication from PE teacher Child PA attitudes and behavior
PE Teacher Focus Group Moderator Guide (Attachment 25)	PYFP PE teachers	6th grade PYFP PE teachers	Professional development PYFP implementation Student recognition and communication School environment Resources and supports needed for the PYFP
Student Focus Group Moderator Guide (Attachment 26)	6th grade students	Students enrolled in 6th grade PE at PYFP schools	Impressions of the PYFP Fitness assessments School supports for PA Student recognition

Fitness Assessment and Accelerometry. Fitness assessments and accelerometry data collection activities will be conducted with 6^th grade students enrolled in PYFP and non-PYFP schools. Exhibit A.1.-7 provides an overview of the measures and the data captured from each. Protocols and data collection forms have been developed for fitness assessments (Attachment 27 FitnessGram® Data Collection Protocol, Attachment 28 FitnessGram Data Collection Form, Attachment 29 Pacer Individual Score Sheet) and accelerometry (Attachment 30 Accelerometry Data Collection Protocol, Attachment 31 Accelerometry Log, Attachment 32 Accelerometry Data Collection - Instructions for PE Teachers, Attachment 33 Accelerometry Belt Instructions and Attachment 34 Accelerometry School Liaison Data Collection Checklist).

Exhibit A.1-7. Measurement Types and Data Captured

Measurement Type	Data Captured From Measurement
FitnessGram® Pacer Assessment	Number of laps completed Used to calculate level of physical fitness
FitnessGram® Body Composition Assessment	Height and weight Used to calculate BMI
Accelerometry (ActiGraph GT3X+)	Bouts of PA over 7 days Used to calculate % time engaged in PA

A crosswalk of the PYFP evaluation questions, data collection types and instrument items is provided in Attachment 42 (Attachment 42 Evaluation Question and Instrument Crosswalk).

A.2 Purpose and Use of Information Collection

A.2.a Purpose of Information Collection

The findings from this evaluation will be used to demonstrate the impact of the PYFP on PE teacher-, school- and student-level outcomes. The mixed-method approach in PYFP schools will allow the evaluation team to assess changes resulting from the PYFP and barriers and facilitators to implementation. This will allow the PYFP program to understand areas of program strength and areas in need of refinement. In addition, cost and implementation questions will allow the team to assess if funding is sufficient and if any efficiencies can be implemented to decrease cost while maintaining impact.

Data collection for the PYFP Evaluation will be used in multiple ways. First, the results from this evaluation will be used to develop reports to be shared with PYFP and program partners as well as other stakeholder groups. Second, PYFP evaluation data will be used to develop a manuscript presenting the impact of the PYFP when compared with a traditional PE curriculum. Third, data from focus groups and cost and time questionnaires will be shared with PYFP leadership and program partners to identify gaps and areas for program improvement.

A.3 Use of Improved Information Technology and Burden Reduction

The primary mode of data collection for PYFP and non-PYFP PE teachers and school administrators will be web-based surveys hosted by SurveyMonkey®. The electronic instruments reduces the burden on respondents to access, complete and submit surveys which is an important consideration given the schedule demands of these respondents. To meet the needs of all respondents, hardcopy surveys, consent forms and self-addressed envelopes will be available upon request and distributed to respondents by the school liaison. Hard copies will also be mailed automatically to those respondents with no known email address. Students will be administered paper copies of surveys.

To assess student PA behavior, the evaluation team will use ActiGraph GT3X+. Use of this technology is less burdensome on respondents than completing daily PA logs and is less expensive than having an evaluation team conduct in-person observation of PA.

A.4 Efforts to Identify Duplication and Use of Similar Information

The data collection activities proposed in this ICR do not duplicate existing efforts. This is the first outcome evaluation of the PYFP to be conducted.

A.5 Impact on Small Businesses or other Small Entities

The planned data collection does not involve small businesses or other small entities.

A.6 Consequences of Collecting the Information Less Frequently

This is a one-time data collection. Without this study, CDC will lack detailed information about the PYFP and program outcomes. Data collection has been planned to occur in PYFP schools during the last year of program funding, allowing evaluation activities to be conducted at the end of the program. If data collection were to occur less frequently, the evaluation team would miss the opportunity to conduct evaluation activities while the schools were still participating in the PYFP.

A.7 Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

This request fully complies with the regulation of 5 CFR 1320.5.

A.8 Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

A.8.a Federal Register Announcement

CDC published a Federal Register notice of the proposed data collection on [June 14, 2016] (Vol. 81, Number 114, Page 38705-38707) (see Attachment 2a). One public comment(s) was/were received and acknowledged (see Attachment 2b).

A.8.b Consultation with Various User Communities and Experts

The PYFP Evaluation team consulted with CDC Subject Matter Experts and with persons outside of CDC when developing the study design. Exhibits A.8-1 and A.8-2 provide information about the subject matter experts.

Exhibit A.8-2= Subject Matter Experts at CDC Consulted for the PYFP Evaluation

Name	Organization	Contact Information
Sarah M. Lee, PhD	Division of Population Health, School Health Branch	Phone: 770-488-6126 [email protected]
Seraphine Pitt Barnes, PhD	Division of Population Health, School Health Branch	Phone: 770-488-6115 s[email protected]

Exhibit A.8-2 Subject Matter Experts outside of CDC Consulted for the PYFP Evaluation

Name	Organization	Contact Information
Jane Wargo	Presidential Youth Fitness Program	Phone: 404-321-3211 [email protected]
Carole Harris, PhD	ICF	Phone: 404-321-3211 [email protected]
Isabela Lucas	ICF	Phone: 404-321-3211 [email protected]
Simone Boyce, PhD	ICF	Phone: 404-321-3211 [email protected]
Stephanie Frost, PhD	ICF	Phone: 404-321-3211 [email protected]
Alice Roberts, MA	ICF	Phone: 301-572-0290 [email protected]
Jill Trott, BS	ICF	Phone: [email protected]
Kelli Cain, MA	University of California, San Diego	Phone: (619) 260-5541 [email protected]
James Sallis, PhD	University of California, San Diego	Phone: 619-260-5535 [email protected]
Tina Kauh, MS, PhD	Robert Wood Johnson Foundation	Phone: 609 627-5933 [email protected]

A.9 Explanation of Any Payment or Gift to Respondents

Obtaining high response rates is critical to the rigor of the evaluation. The PYFP evaluation team will provide respondents with gifts of appreciation for their participation and will be paid for from CDC contract funds awarded to ICF. Parents and teachers participating in focus groups outside of school hours will receive $15 gift cards. For teachers who participate in focus groups during school hours, no tokens of appreciation will be provided. Students participating in the focus groups will receive a non-monetary prize equivalent to $15. Students participating in accelerometry data collection will receive a non-monetary prize equivalent to $15 after the first week of wear-time and $35 after the second week of wear-time at the end of the semester. ICF will create age-appropriate packages, equivalent to $15 and $35, of items such as: school supplies (pens, notebooks, school logo items, t-shirts), physical activity items (sports equipment), or other items (movie tickets, head phones) that have been approved by the schools. Students participating in accelerometry data collection will be asked to wear accelerometers for a full week at the beginning and end of the PE semester (two weeks total). In addition to wearing the accelerometer, students will be asked to keep a brief activity log of when they wore their accelerometer, along with their class schedule for each day. At the end of the week, students will return the accelerometers, the activity log and the class schedule to the school liaison. As an additional incentive, there will also be a drawing for a non-monetary prize equivalent to $100 for students participating in accelerometry data collection. Students will receive one entry into the drawing for each day they wear the accelerometer. The drawing is used to ensure 4 or more days of wear-time. ICF has used this approach in the past and it greatly improved wear-time and completeness of data.

A.10 Protection of the Privacy and Confidentiality of Information Provided by Respondents

The Privacy Act applies to the PYFP evaluation because information in an identifiable form will be collected in order to link fitness assessment and accelerometry data collected at the beginning and end of the PE semester. The existing applicable System of Records Notice (SORN) for this information collection is Privacy Act System Notice 09-20-0160, “Records of Subjects in Health Promotion and Education Studies” (51 FR 42484), and is being submitted with this . However, names will only be viewable to a small number of trained ICF staff and located in password protected files on a secure server. In addition, names will only be used to link to an ID number. ICF will not collect any personally identifiable information through focus groups or surveys administered on paper or through Survey Monkey. Information in identifiable form will not be transmitted to CDC. Once beginning and end of semester data are merged, the file linking student names and ID numbers will be destroyed.

All procedures have been developed in accordance with federal, state and local guidelines to ensure that the rights of participants are protected and data are appropriately safeguarded.

Privacy Impact Assessment Information

1. Privacy Act Determination.

Names will be included on consent forms and tracking databases used by the ICF evaluation team. The data management team lead will enter names into a locked database where a unique ID will be associated with each participant name. Only members of the ICF evaluation team and school liaisons will have access to this database which will be stored on a secure ICF server. IDs will be used when collecting fitness assessment and accelerometry data and names will never be associated with participant data. Also, because students in selected classrooms will participate in fitness assessments and accelerometry at the beginning and end of the semester, student names will be used to link data from the two time points together. All information will be maintained confidentially and de-identified once the study is completed. Names of study participants will not be included in any files shared with CDC and will never be reported or published.

2. Information Security.

ICF will use its secure servers to protect and maintain information collected through the PYFP Evaluation. Identifying information will be kept in password-protected files on a secure server accessible only through password-protected computers. Respondent names will be linked to unique identification numbers to link respondents to schools or link data collected at the beginning and end of the semester. Names will be kept separate from data in a different password-protected file on the secure server. Data will be analyzed and reported in aggregate. Respondents will not be asked to report identifying information on surveys, during focus groups or on accelerometry logs.

3. Consent.

Consent forms will include the following: 1) the description and purpose of the data collection, 2) the voluntary nature of participation, including the ability to stop/skip questions at any time, 3) the risks and benefits of participation, 4) the gift for participation and 5) the contact information of the principal investigator.

Web-based Consent. The survey consent page will appear when the respondent (PE teachers and school administrators) first opens the survey link (Attachment 36 PE Teacher Survey Consent, Attachment 37 School Administrator Survey Consent – Online Survey). If the respondent agrees to participate consent is actively conferred by selecting the next button to start the survey.

Hardcopy Consent. As noted earlier, the evaluation team will seek active parent consent for student participation in the accelerometry substudy and for focus group participation (Attachments 13a & 13b - Parent Letters – Passive Consent Survey and Fitness Assessments, Attachment 15 – Parent Accelerometer Consent Form). We will seek passive consent for student participation in surveys and fitness assessments unless the school requires active consent (Attachments 16a & 16b – Parent Letter – Active Consent Survey and Fitness Assessments). The evaluation team will obtain written consent from PE teachers and parents for focus group participation as a first step in the focus group protocols (Attachment 38 – PE Teacher Focus Group Participation Consent Form, Attachment 39 – Parent Focus Group Consent Form). The evaluation team will also confirm student assent for accelerometry and focus group participation (Attachment 40 Accelerometry Student Assent and Attachment 41 Student Focus Group Assent).

4. Voluntary Nature of Participation.

Participation in the PYFP Evaluation is voluntary and respondents can discontinue participation at any time.

A.11 Institutional Review Board and Justification for Sensitive Questions

The ICF Institutional Review Board (IRB) reviewed and approved all instruments, informed consent forms and recruitment materials for the PYFP Evaluation as of 9/19/2016. ICF’s IRB approval memorandum is included as Attachment 35. CDC IRB approval was not necessary for this evaluation. It is important to note that the focus is an evaluation of a specific program and the intent is not to conduct research and produce generalizable data.

The data collected through the PYFP Evaluation is related to PE and PA. Respondents will not be asked to report on sensitive topics.

A.12 Estimates of Annualized Burden Hours and Costs

A.12.a Estimated Burden Hours

OMB approval is requested for two years (2016-2018). Exhibit A.12-1 provides a summary of data collection scheduled to occur during this period. Respondents will participate in surveys and focus groups one time and students will participate in fitness assessment and accelerometry twice (beginning of semester and end of semester). Approximately 11 PYFP and 11 non-PYFP middle schools will participate in the PYFP evaluation. One administrator per school will be asked to participate in the administrator survey and all 6^th grade PE teachers will participate in surveys (PYFP and non-PYFP schools) and focus groups (select PYFP schools only). Using data obtained from the PYFP application database, we estimate an average of four 6^th grade PE teachers per school. For students, we estimate an average of 4 6^th grade PE classes per school with 30 students per class. For accelerometry data collection we will recruit 10 student from 25 PYFP and 25 non-PYFP PE classes (500 students). Of those expressing interest/giving permission to participate in focus groups, the evaluation team will select up to 10 PE teachers, students and parents to participate for each of the participating schools. Focus groups will be conducted in a subset of six PYFP schools. The estimated annualized burden is provided in Exhibit A.12-1.

Exhibit A.12-1 Estimated Annualized Burden Hours

Type of Respondents	Form Name	No. of Respondents	No. of Responses per Respondent	Average Burden Per Response (in hours)	Total Burden (in hours)
6th grade students in PYFP Schools	FitnessGram® Data Collection Form	615	2	15/60	308
	Accelerometry Log	125	2	30/60	125
	Student Survey (PYFP Schools)	615	1	15/60	154
	Student Focus Group Moderator Guide	30	1	1	30
PE teachers in PYFP Schools	PE Teacher Survey (PYFP Schools)	22	1	25/60	9
	PE Teacher Focus Group Moderator Guide	12	1	1	12
	PYFP Time Use Worksheet	6	1	30/60	3
School administrators in PYFP Schools	School Administrator Survey (PYFP Schools)	6	1	20/60	2
	PYFP Cost Worksheet	6	1	1	6
Parents of 6th graders enrolled in PE at PYFP Schools	Parent Focus Group Moderator	30	1	1	30
6th grade students in non-PYFP Schools	FitnessGram® Data Collection Form	615	2	15/60	308
	Accelerometry Log	125	2	30/60	125
	Student Survey (non-PYFP Schools)	615	1	15/60	154
PE teachers in non-PYFP Schools	PE Teacher Survey (non-PYFP Schools)	22	1	20/60	8
School Administrators in non-PYFP Schools	School Administrator Survey (non-PYFP Schools)	6	1	20/60	2
Total					1276

Exhibit A.12-2 presents the calculations for the estimated cost of respondent hours. The annual cost to respondents is estimated to be $7085.89.

Exhibit A.12-2 Estimated Annual Cost to Respondents

Type of Respondent	Form Name	No. of Respondents	No. of Responses per Respondent	Average Burden Per Response (In Hours)	Hourly Wage Rate	Total Respondent Costs
6th grade students (PYFP)	FitnessGram® Data Collection Form	615	2	15/60	$4.25	$1306.88
	Accelerometry Log	125	2	30/60	$4.25	$531.25
	Student Survey (PYFP Schools)	615	1	15/60	$4.25	$653.44
	Student Focus Group Moderator Guide	30	1	1	$4.25	$127.50
PE teacher (PYFP)	PE Teacher Survey (PYFP Schools)	22	1	25/60	$27.07	$248.14
	PE Teacher Focus Group Moderator Guide	12	1	1	$27.07	$324.84
	PYFP Time Use Worksheet	6	1	30/60	$27.07	$81.21
School Administrator (PYFP)	School Administrator Survey (PYFP Schools)	6	1	20/60	$43.05	$86.1
	PYFP Cost Worksheet	6	1	1	$43.05	$236.78
Parents of 6th graders enrolled in PE at PYFP Schools	Parent Focus Group Moderator Guide	30	1	1	$24.49	$734.70
6th grade students in non-PYFP Schools	FitnessGram® Data Collection Form	615	2	15/60	$4.25	$1306.88
	Accelerometry Log	125	2	30/60	$4.25	$531.25
	Student Survey (non-PYFP Schools)	615	1	15/60	$4.25	$653.44
PE teachers in non-PYFP Schools	PE Teacher Survey (non-PYFP Schools)	22	1	20/60	$27.07	$198.51
School Administrators in non-PYFP Schools	School Administrator Survey (non-PYFP Schools)	6	1	20/60	$43.05	$86.10
TOTAL	$7,107.02

A.13 Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

There will be no respondent capital and maintenance costs.

A.14 Annualized Cost to the Government

The study is funded under Contract No. 200-2014-61001-0003. The total contract award to ICF Macro is $1.5 million over a 36-month period. Thus the annualized contract cost is approximately $500,000. These costs cover the activities in Table A-14 below.

Additional costs will be incurred indirectly by the government in personnel costs of staff involved in oversight of the study and in conducting data analysis. It is estimated that 2 CDC employees will be involved for approximately 20% and 15% of their time at salaries of $60 and $50 per hour, respectively. . The direct annual costs in CDC staff time will approximate $40,560 annually. The total cost for the study over a 24-month period, including the contract cost and federal government personnel cost is $1,081,120. The annualized cost to the government for the study will be $540,560.

Exhibit A.14-1 Itemized Annual Cost to the Federal Government

Activity	Total Respondent Costs
Contract Costs
Recruitment (schools, school liaisons and respondents)	$90,390
Data collection	$255,469
Data Management & Analysis	$75,678
Reporting & Dissemination	$118,923
Subtotal	540,460
Federal Employee Time Cost – GS-14 at 20%	$24,960
Federal Employee Time Cost – GS-13 at 15%	$15,600
Average Annualized Cost	$581,020

A.15 Explanation for Program Changes or Adjustments

This is a new, one-time data collection.

A.16 Plans for Tabulation and Publication and Project Time Schedule

A.16.a Tabulation Plans

ICF staff will create data sets that can be used in analyses for each of the instruments and measures administered to respondents. The process for data preparation involves the following:

• Assessment of nonresponse or missing data

• Performance checks of data quality: completeness of data, verify accuracy, check validity and examine summary statistics

• Implementation of procedures to address any data quality issues

The approach to analysis will include calculation of summary statistics to examine teaching practices; characterize the school environment; assess student attitudes and behavior. The evaluation team will examine change over the course of the semester with regard to PA levels and fitness as well as differences in PE teacher practices, student PA, student fitness and the school environment between PYFP and non-PYFP schools. Logistic regression will be used to assess the impact of PE teacher practices and the school environment on student outcomes in PYFP and non-PYFP schools.

Software such as MeterPlus will be used to analyze student accelerometry data and SPSS or STATA will be used for all quantitative analyses. Analyses will be performed on data aggregated by school type (PYFP versus non-PYFP). Descriptive analyses will summarize central tendencies and measures of dispersion for continuous data and proportional distributions for nominal, interval and ratio data.

Qualitative data will be analyzed using AtlasTI. The evaluation team will develop a thematic codebook with deductive codes associated with the evaluation questions and questions from each of the interview and focus group guides. The single codebook will be used to analyze qualitative data across all data sources and will include definitions as well as inclusion and exclusion criteria for each thematic code. Thematic codes will be applied to all relevant narrative text segments, and any relevant inductive codes that arise will be added. Coding will be conducted by a two-person team, following a detailed process of establishing and maintaining at least 80% intercoder reliability.

A.16.b Publication Plans

The results from the PYFP evaluation will be developed into an overall report and presentation shared with PYFP partners and stakeholders. There will also be a manuscript developed for publication in a peer-reviewed journal highlighting key evaluation findings and lessons learned. The final report, presentation and manuscript will be prepared during quarter 4 of 2018.

A.16.c Time Schedule for the Project

It is important to note that the Youth Risk Factor Survey (YRBS) and National Youth Tobacco Survey (NYTS) occur in spring. PYFP Evaluation data collection activities are planned to occur in the spring in Year 1. No overlap is expected with the NYTS, as it is administered to high school students. Although the YRBS is administered in middle schools, the PYFP Evaluation team has contacted the project lead for the YRBS and determined there is little chance for overlap between projects. To ensure that the PYFP does not approach the same middle schools participating in the YRBS, the project lead for the YRBS has offered to review the list of PYFP and non-PYFP schools and note if there any schools appearing on both lists. If a school has been identified for participation in both the YRBS and PYFP Evaluation, the PYFP evaluation team will identify a new school.

Table A.16.c. Time Schedule for Key Project Activities

Activity	Apx. months after OMB approval	Optimal Dates
Wave 1 – Round 2 Schools
Recruit Round 2 schools and school liaisons	Upon approval	Oct-November 2016
Train schools liaisons	2 mos.	December 2016
Recruit respondents (Wave 1 – spring 2017)	3 mos.	January 2017
Collect beginning of semester student data (fitness assessment and accelerometry)	3-4 mos.	January-February 2017
Clean and analyze Wave 1 beginning of semester data	4-6 mos.	February-April 2017
Administer PE cost worksheets	6 mos.	April 2017
Collect Wave 1 end of semester student, PE teacher, school administrator and parent data	7-8 mos	May-June 2017
Merge Wave 1 end of semester student data with beginning of semester student data, analyze Wave 1 end of semester data and develop reports	8-11 mos.	June-September 2017
Activity	Apx. months after OMB approval	Optimal Dates
Wave 2 – Round 3 Schools
Recruit Round 3 schools and school liaisons	9-10 mos.	July-August 2017
Train school liaisons	10-11 mos.	August-September 2017
Recruit respondents (Wave 2 – fall 2017)	11 mos.	August-September 2017
Collect Wave 2 beginning of semester student data (fitness assessment and accelerometry)	11-12 mos.	September-October 2017
Clean and analyze Wave 2 beginning of semester data	12-13 mos.	October-November 2017
Administer PE cost worksheets	13 mos.	November 2017
Collect and of wave 2 end of semester student, PE teacher, school administrator and parent data	13-14 mos.	November - December 2017
Merge Wave 2 end of semester student data with beginning of semester student data, analyze Wave 2 end of semester data and develop reports	14-17 mos.	December 2017-March 2018
Merge Wave 1 and Wave 2 data, analyze data and develop reports	16-19 mos.	February-May 2018
Write report and manuscript	18-23 mos.	April-September 2018

A.17 Reason(s) Display of OMB Expiration Date is Inappropriate

The expiration date of OMB approval of data collection will be displayed.

A.18 Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

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1 Because the definition of middle school can vary by jurisdiction, we are defining middle school as a school with a 6^th grade.