TRP and Confidentiality

2012/17 Beginning Postsecondary Students Longitudinal Study: (BPS:12/17)

Full Scale Interview and Administrative Record Collections

August 2016

Appendixes A and B

Appendix A: Technical Review Panel (TRP) Members A-1

Appendix B: Confidentiality for Administrative Record Matching B-1

Appendix A
Technical Review Panel (TRP) Members

Technical Review Panel

Michelle Appel
Director, Assessment and Decision Support
University of Maryland
1101 Mitchell Building
College Park, MD 20742
Phone: (301) 405-0475
Email: [email protected]

Teresita Bazan
Executive Director of Student Assistance
Austin Community College
5930 Middle Fiskville Road
Austin, TX 78752
Phone: (512) 223-7550
Email: [email protected]

Angela Bell
Senior Executive Director of Research and Policy Analysis
University System of Georgia
207 Washington Street SW
Atlanta, GA 30334
Phone: (404) 962-3069
Email: [email protected]

Alberto Cabrera
Professor
University of Maryland
3112 Benjamin Building
College Park, MD 20742
Phone: (301) 405-2875
Email: [email protected]

Margaret Cahalan
Vice President for Research & Director Council for Opportunity in Education
The Pell Institute
1025 Vermont Avenue NW
9th Floor
Washington, DC 20005
Phone: (202) 347-7430
Email: [email protected]

Stephanie Cellini

Associate Professor of Public Policy and Economics

George Washington University

805 21^st Street NW

Room 601 M

Washington, DC 20052

Phone: (202) 994-0019

Email: [email protected]

James Cole
Project Manager, Beginning College Survey of Student Engagement
Indiana University
1900 East Tenth Street
Eigenmann Hall, Suite 419
Bloomington, IN 47406
Phone: (812) 856-3004
Email: [email protected]

William Doyle
Associate Professor of Higher Education
Vanderbilt University
230 Appleton Place
Nashville, TN 37203
Phone: (615) 322-2904
Email: [email protected]

Charlotte Etier
Research Analyst
National Association of Student Financial Aid Administrators
1101 Connecticut Avenue NW
Suite 1100
Washington, DC 20036
Phone: (202) 785-6943
Email: [email protected]

Robert Gonyea
Associate Director, Center for Postsecondary Research
Indiana University Bloomington
1900 East 10th Street
Suite 419
Bloomington, IN 47406
Phone: (812) 856-5824
Email: [email protected]

Manuel S. Gonzalez Canche
Assistant Professor
University of Georgia
116 Meigs Hall
Athens, GA 30602
Phone: (706) 583-0048
Email: [email protected]

Jacob Gross
Assistant Professor
University of Louisville
4713 South 6th Street
Louisville, KY 40214
Phone: (502) 724-4453
Email: [email protected]

Taylor Hansen
Director of Legislative & Regulatory Affairs
Association of Private Sector Colleges and Universities
1101 Connecticut Avenue NW
Suite 900
Washington, DC 20036
Phone: (202) 336-6707
Email: [email protected]

Nicholas Hillman
Assistant Professor
University of Wisconsin-Madison
1000 Bascom Mall
Education Building, Room 249
Madison, WI 53706
Phone: (812) 345-1435
Email: [email protected]

Patrick Kelly
Senior Associate and Director
National Center for Higher Education Management Systems
3035 Center Green Drive
Suite 150
Boulder, CO 80301
Phone: (720) 987-3391
Email: [email protected]

Greg Kienzl
Senior Research Associate
ACT, Inc.
One Dupont Circle NW
Suite 220
Washington, DC 20036
Phone: (202) 223-2318
Email: [email protected]

Kent Phillippe
Associate Vice President, Research & Student Success
American Association of Community Colleges
One Dupont Circle NW
Suite 410
Washington, DC 20036
Phone: (202) 416-4505
Email: [email protected]

Jason Ramirez
Director of Research and Policy Analysis
National Association of Independent Colleges and Universities
1025 Connecticut Ave NW
Suite 700
Washington, DC 20036
Phone: (202) 835-0003
Email: [email protected]

Josipa Roksa
Associate Professor of Sociology and Education
University of Virginia, Department of Sociology
P.O. Box 400766
Charlottesville, VA 22904
Phone: (434) 924-6528
Email: [email protected]

Jonathan Smith
Policy Research Scientist
College Board
1919 M Street NW
Suite 300
Washington, DC 20036
Phone: (202) 741-4733
Email: [email protected]

Marvin Titus
Associate Professor, Higher Education
University of Maryland
Benjamin Building, 3209
College Park, MD 20742
Phone: (301) 405-2220
Email: [email protected]

Jonathan Turk
Policy Research Analyst
American Council on Education
One Dupont Circle NW
Suite 1B
Washington, DC 20036
Phone: (202) 939-9321
Email: [email protected]

Mamie Voight
Vice President of Policy Research
Institute for Higher Education Policy (IHEP)
1825 K Street NW
Suite 720
Washington, DC 20006
Phone: (202) 587-4967
Email: [email protected]

Federal Panelists

Daniel Pollard
Senior Advisor, Enterprise Data
U.S. Department of Education, FSA Office of the Chief Operating Officer
830 First Street NE
Washington, DC 20202
Phone: (202) 377-3389
Email: [email protected]

Emilda Rivers
Director, Human Resources Statistics Program
National Science Foundation
4201 Wilson Boulevard
Suite 965 S
Arlington, VA 22230
Phone: (703) 292-7773
Email: [email protected]

Bob Sivinski
Statistician
Office of Management and Budget
725 17th Street NW
Washington, DC 20503
Phone: (202) 395-1205
Email: [email protected]

U.S. Department of Education, NCES

Peggy Carr
Acting Commissioner
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4061
Washington, DC 20202
Phone: (202) 245-6168
Email: [email protected]

Chris Chapman
Associate Commissioner
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4054
Washington, DC 20202
Phone: (202) 245-7103
Email: [email protected]

Elise Christopher
Statistician
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4005
Washington, DC 20202
Phone: (202) 245-7098
Email: [email protected]

Lisa Hudson
Education Statistician
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4013
Washington, DC 20202
Phone: (202) 245-7027
Email: [email protected]

Tracy Hunt-White
Education Statistician
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4007
Washington, DC 20202
Phone: (202) 245-6507
Email: [email protected]

Kashka Kubzdela
OMB Liaison
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP)
Washington, DC 20202
Phone: (202) 245-7377
Email: [email protected]

Gail Mulligan
Longitudinal Surveys Branch Chief
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4178
Washington, DC 20202
Phone: (202) 245-8413
Email: [email protected]

David Richards
BPS Project Officer
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4037
Washington, DC 20202
Phone: (202) 245-6202
Email: [email protected]

Marilyn Seastrom
Chief Statistician
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4063
Washington, DC 20202
Phone: (202) 245-7766
Email: [email protected]

Sean Simone
Statistician
U.S. Department of Education, NCES
550 12th Street SW
Washington, DC 20202
Phone: (202) 245-7631
Email: [email protected]

Ted Socha
Mathematical Statistician
U.S. Department of Education, NCES
550 12th Street SW
Potomac Center Plaza (PCP), Room 4004
Washington, DC 20202
Phone: (202) 245-7071
Email: [email protected]

RTI International

Michael Bryan
Research Education Analyst
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 541-7498
Email: [email protected]

Darryl Cooney
Statistician
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 316-3486
Email: [email protected]

Kristin Dudley
Research Programmer Analyst
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 541-6855
Email: [email protected]

Jeffrey Franklin
Senior Survey Methodologist
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 485-2614
Email: [email protected]

Jason Hill
Director, BPS: 12/17
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 541-6425
Email: [email protected]

Nicole Ifill
Research Education Analyst
RTI International
701 13th Street NW
Suite 750
Washington, DC 20005
Phone: (202) 600-4295
Email: [email protected]

T. Austin Lacy
Research Education Analyst
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 990-8386
Email: [email protected]

Alexandria Radford
Associate Director, Postsecondary Education
RTI International
701 13th Street NW
Suite 750
Washington, DC 20005
Phone: (202) 600-4296
Email: [email protected]

David Wilson
Senior Statistician/Statistical Task Leader
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 541-6990
Email: [email protected]

Jennifer Wine
Director, Program in Education Survey Design
RTI International
3040 East Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone: (919) 541-6870
Email: [email protected]

Appendix B
Confidentiality for Administrative Record Matching

B.1 Develop Linkages with Administrative Data Sources

Linkages will be developed with existing data sources to supplement the 2012/17 Beginning Postsecondary Students Study (BPS:12/17). NCES recognizes the great value added to the BPS:12/17 data file with the addition of data from specific administrative data sources as certain data, such as specific financial aid amounts and associated dates, can only be accurately obtained from sources other than the student. Our postsecondary studies, including the National Postsecondary Student Aid Study (NPSAS) and the Baccalaureate and Beyond Longitudinal Study (B&B), have included file merges with many existing sources of valuable data, including Department of Education’s (ED) Central Processing System (CPS) for Free Application for Federal Student Aid (FAFSA) data, the National Student Loan Data System (NSLDS), and National Student Clearinghouse (NSC). For this study, we plan to perform file merges with the following datasets: CPS, NSLDS, and NSC.

The Family Educational Rights and Privacy Act (FERPA) (34 CFR Part 99) allows the disclosure of personally identifiable information from students’ education records without prior consent for the purposes of BPS:12/17 according to the following excerpts: 34 CFR § 99.31 asks, “Under what conditions is prior consent not required to disclose information?” and explains in 34 CFR § 99.31(a) that “An educational agency or institution may disclose personally identifiable information from an education record of a student without the consent required by §99.30 if the disclosure meets one or more” of several conditions. These conditions include, at 34 CFR § 99.31(a)(3):

“The disclosure is, subject to the requirements of §99.35, to authorized representatives of--

(i) The Comptroller General of the United States;

(ii) The Attorney General of the United States;

(iii) The Secretary; or

(iv) State and local educational authorities.”

BPS is collecting data under the Secretary’s authority. Specifically, NCES, as an authorized representative of the Secretary of Education, is collecting this information for the purpose of evaluating a federally supported education program. Any personally identifiable information is collected with adherence to the security protocol detailed in 34 CFR § 99.35:

(a)(1) Authorized representatives of the officials or agencies headed by officials listed in §99.31(a)(3) may have access to education records in connection with an audit or evaluation of Federal or State supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs.

(2) The State or local educational authority or agency headed by an official listed in §99.31(a)(3) is responsible for using reasonable methods to ensure to the greatest extent practicable that any entity or individual designated as its authorized representative—

(i) Uses personally identifiable information only to carry out an audit or evaluation of Federal- or State-supported education programs, or for the enforcement of or compliance with Federal legal requirements related to these programs;

(ii) Protects the personally identifiable information from further disclosures or other uses, except as authorized in paragraph (b)(1) of this section; and

(iii) Destroys the personally identifiable information in accordance with the requirements of paragraphs (b) and (c) of this section.

(b) Information that is collected under paragraph (a) of this section must—

(1) Be protected in a manner that does not permit personal identification of individuals by anyone other than the State or local educational authority or agency headed by an official listed in §99.31(a)(3) and their authorized representatives, except that the State or local educational authority or agency headed by an official listed in §99.31(a)(3) may make further disclosures of personally identifiable information from education records on behalf of the educational agency or institution in accordance with the requirements of §99.33(b); and

(2) Be destroyed when no longer needed for the purposes listed in paragraph (a) of this section.

(c) Paragraph (b) of this section does not apply if:

(1) The parent or eligible student has given written consent for the disclosure under §99.30; or

(2) The collection of personally identifiable information is specifically authorized by Federal law.

Secure Data Transfers. NCES has set up a secure data transfer system, using the NCES member site with Secure Sockets Layer (SSL) technology. The contractor will use this electronic system for submitting data containing potentially identifying information (such as SSNs, names, and dates of birth of our sample members) along with their survey ID (not the same ID that is available on the restricted-use data). Before being transmitted, files will be encrypted using FIPS 140-2 validated encryption tools. Data will be received from the NCES system as well. The system requires that both parties to the transfer be registered users of the NCES Members Site and that their Members Site privileges be set to allow use of the secure data transfer service as described above. This process will be used for file matching procedures described below, except in instances when the vendor already has a secure data transfer system in place.

B.2 File Merge with ED Central Processing System (CPS)

File merges will be performed by the data collection contractor with the CPS data containing federal student aid application information. The merge with CPS can occur at any time for any number of cases, provided that the case has an apparently valid SSN associated with it. A file will be sent to CPS and in return a large data file containing all matched students who applied for federal aid will be received. The data collection contractor has programs and procedures in place to prepare and submit files according to rigorous CPS standards, and to receive and process data obtained from CPS.

A file will be electronically uploaded on the FAFSA secure web-site for matching which contains SSN and the first 2 letters of the sample member’s last name (but no other information). Access to the site for the upload is restricted to authorized users who are registered and provide identification/authentication information (user name, password, and token key) to the FAFSA data site. The file is retrieved by the Central Processing System or CPS (the FAFSA contractor data system) for linkage. The linked file, containing student aid applications for matched records, is then made available to us only through a secure connection (EdConnect) which also requires user name, password, and a token key. All CPS files will be processed, edited, and documented for inclusion in the final restricted use file (RUF).

B.3 File Merge with National Student Loan Data System (NSLDS) Disbursement

A file merge will be conducted with the NSLDS to collect federal loan and Pell grant data. The resulting file will contain cumulative amounts for each student’s entire postsecondary education enrollment. NCES has set up a secure data transfer system that uses their NCES member site and Secure Sockets Layer (SSL) technology. The system requires that both parties to the transfer be registered users of the NCES Members Site and that their Members Site privileges be set to allow use of the secure data transfer service. These privileges are set up and carefully controlled by the ED’s Institute of Education Sciences (IES) NCES Chief Technology Officer (CTO), a service designed by ED/NCES specifically for the secure transfer of electronic files containing personally identifying information (i.e., data protected under the Privacy Act or otherwise posing risk of disclosure), and can be used for NCES-to-Contractor; Contractor-to-Subcontractor; Subcontractor-to-Contractor; and Contractor-to-Other-Agency data transfers. The party uploading the information onto the secure server at NCES is responsible for deleting the file(s) after the successful transfer has been confirmed. Programs have been developed to create the files for the merge and also to read the data received. All matching processes are initiated by the data collection staff providing a file with one record per sample member to be merged.

B.4 File Merge with the National Student Clearinghouse (NSC)

The NSC will be used to obtain its “Student Tracker” data, which include student-level data, provided by participating institutions, on institutions attended, enrollment dates, and degree completions for the BPS:12/17 sample.

The data collection contractor will first set up an account with the Clearinghouse which will enable sending and receiving of files securely over encrypted FTPS connections. The file containing sensitive student identifiers (name, date of birth, and SSN) will be encrypted using FIPS 140-2 validated encryption tools then submitted to the Clearinghouse using their secure FTP site. All files received by the Clearinghouse will be securely stored using FIPS 140-2 validated AES encryption, the US federal encryption standard. Matched files, containing data on enrollment dates, institution names, and degrees completed, will be returned to the data collection contractor using the same secure FTP site.

B.5 Processing Administrative Data

We propose to send files for matching during data collection. We may need to match to a source (e.g., CPS or NSLDS) more than once during the full-scale study.

The data from all of these sources, as allowed by the vendor, will be delivered for inclusion on the RUF and will be useful for creating derived variables. The derived variables will be available on PowerStats and QuickStats, and both direct-pull and derived variables will be documented thoroughly. Data from CPS and NSLDS will also be useful for purposes of locating the sample.