2019–20 NATIONAL POSTSECONDARY STUDENT AID STUDY (NPSAS:20)
Institution Contacting and List Collection
Supporting Statement Part A
OMB # 1850-0666 v.23
Submitted by
National Center for Education Statistics
U.S. Department of Education
April 2019
Contents
A. Justification 1
1. Circumstances Making Collection of Information Necessary 1
a. Purpose of this Submission 1
b. Legislative Authorization 1
c. Prior NPSAS Studies 2
d. Prior and Related Studies 3
2. Purposes and Uses of the Data 3
a. NPSAS:20 Purposes 3
b. NPSAS:20 Research and Policy Issues 4
3. Use of Information Technology 5
4. Efforts to Identify Duplication 6
5. Method Used to Minimize Burden on Small Businesses 6
6. Frequency of Data Collection 6
7. Special Circumstances of Data Collection 7
8. Consultants Outside the Agency 7
9. Provision of Payments or Gifts to Respondents 7
10. Assurance of Confidentiality 7
11. Sensitive Questions 10
12. Estimates of Response Burden 10
13. Estimates of Cost 11
14. Costs to Federal Government 11
15. Reasons for Changes in Response Burden and Costs 11
16. Publication Plans and Time Schedule 12
17. Approval to Not Display Expiration Date for OMB Approval 12
18. Exceptions to Certification for Paperwork Reduction Act Submissions 12
B. Collection of Information Employing Statistical Methods
Appendixes
Technical Review Panel Members
Endorsing Organizations for NPSAS:20
Confidentiality for Administrative Record Matching
Institution Contacting Materials
Table 1. Chronology of NPSAS and its longitudinal components 3
Table 2. Average estimated burden to institution respondents for the NPSAS:20 data collection 11
Table 3. Costs to NCES for the NPSAS:20 full-scale study 11
Table 4. Operational schedule for NPSAS:20 12
This request is to conduct the 2019–20 National Postsecondary Student Aid Study Institution Contacting and List Collection (NPSAS:20). This study is being conducted by the National Center for Education Statistics (NCES), within the Institute of Education Sciences (IES), part of the U.S. Department of Education. The primary contractor for this study is RTI International (Contract# 91990018C0039). Subcontractors for NPSAS:20 include Leonard Resource Group; HR Directions; KForce Government Solutions, Inc.; Research Support Services; EurekaFacts; Strategic Communications; and Activate Research. Dr. Anthony Jones, Dr. Sandy Baum, and Dr. Stephen Porter are consultants for the study.
This submission covers materials and procedures related to institution sampling, enrollment list collection, and matching to administrative data files as part of the NPSAS:20 data collection. NCES will submit a separate clearance package covering the student data collection, including student record data abstraction and student interviews, in the summer of 2019. The materials and procedures are based on those developed for previous institution-based data collections, including the 2015–16 National Postsecondary Student Aid Study (NPSAS:16) [OMB #1850-0666 v.17], the 2012 Beginning Postsecondary Students Longitudinal Study (BPS:12) student record collection [OMB #1850-0631 v.10], and the 2018 National Postsecondary Student Aid Study Administrative Collection (NPSAS:18-AC) [1850-0666 v.21]. With those submissions, NCES adequately justified the need for and overall practical utility of the full study, an overarching plan for all phases of the data collection, and provided as much detail on the measures to be used. As part of this submission, NCES is publishing a notice in the Federal Register allowing first a 60- and then a 30-day public comment period.
The first NPSAS was implemented by NCES during the 1986–87 academic year to meet the need for national data about significant financial aid issues. Since 1987, NPSAS has been fielded every 3 to 4 years, most recently during the 2015–16 academic year (NPSAS:16). NPSAS:20 will be both nationally- and state-representative. The NPSAS:20 sample will include 125,000 nationally-representative undergraduate and 25,00 nationally-representative graduate students who will be asked to complete an interview and for whom we will collect student records and administrative data. The sample will be augmented with an additional 250,000 sample undergraduate students to create state-representative samples for undergraduate students overall and in public 2-year and public 4-year institutions. These additional students will not be asked to complete an interview; we will only have student records and administrative data. The entire sample of 375,000 undergraduates will also be nationally-representative for estimates based on student records and administrative data. Also, NPSAS:20 will serve as the base year for the 2020 cohort of the Beginning Postsecondary Students (BPS) Longitudinal Study and will include a nationally-representative sample of first-time beginning students (FTBs). Subsets of questions in the student interview will focus on describing aspects of the experience of beginning students in their first year of postsecondary education, including student debt and education experiences.
This submission describes the planned sampling, recruitment, and data collection procedures, and includes
a list of individuals on the NPSAS:20 Technical Review Panel (TRP) (appendix A);
a list of institutions and associations endorsing and supporting NPSAS:20 (appendix B);
a description of the confidentiality procedures in place for the administrative record matching (appendix C); and
contacting materials for institution staff providing enrollment lists (appendix D).
While changes to this submission are not anticipated, if NCES or its data collection contractor is unable to secure an agreement with any of the listed desired administrative data providers, a change request will be submitted.
NCES conducts NPSAS:20 in close consultation with other U.S. Department of Education offices, federal agencies, and organizations (see sections A.4 and A.8 of this document). NCES is authorized to conduct NPSAS under the Education Sciences Reform Act of 2002 (ESRA 2002, 20 U.S.C. §9543) and the Higher Education Opportunity Act of 2008 [HEOA 2008, 20 U.S.C. §1015(a)(k)]:
(1) Survey required: The Secretary, acting through the Commissioner for Education Statistics, shall conduct, on a State-by-State basis, a survey of recipients of Federal student financial aid under subchapter IV of this chapter and part C of subchapter I of chapter 34 of title 42—
(A) to identify the population of students receiving such Federal student financial aid;
(B) to describe the income distribution and other socioeconomic characteristics of recipients of such Federal student financial aid;
(C) to describe the combinations of aid from Federal, State, and private sources received by such recipients from all income categories;
(D) to describe the—
(i) debt burden of such loan recipients, and their capacity to repay their education debts; and
(ii) the impact of such debt burden on the recipients’ course of study and post-graduation plans;
(E) to describe the impact of the cost of attendance of postsecondary education in the determination by students of what institution of higher education to attend; and
(F) to describe how the costs of textbooks and other instructional materials affect the costs of postsecondary education for students.
(2) Frequency: The survey shall be conducted on a regular cycle and not less often than once every four years.
(3) Survey design: The survey shall be representative of students from all types of institutions, including full-time and part-time students, undergraduate, graduate, and professional students, and current and former students.
(4) Dissemination: The Commissioner for Education Statistics shall disseminate to the public, in printed and electronic form, the information resulting from the survey.”
As noted above, NPSAS:20 will be the eleventh NPSAS in a series dating back to 1987. Since its inception, the data collection techniques, sources, and sampling and weighting methods used for NPSAS have been updated to meet increasing demand for more precise and detailed information to inform postsecondary student financial aid policy. The first study in the series, NPSAS:87, combined paper-based surveys of 40,000 students enrolled in postsecondary education in the fall term of 1986 and a subset of their parents with institutional records. NPSAS:90 expanded the sample to students enrolled in postsecondary education at any time during a full academic year, so that students enrolled only during the summer or spring terms, as well as those who began at any time in institutions not on a traditional calendar system (primarily vocational institutions), were included. NPSAS:90 also introduced computer-assisted telephone interviewing and incorporated data from the federal Pell Grant payment file. NPSAS:93 enabled institutions to enter student records electronically, and NPSAS:96 added as data sources the Central Processing System (CPS) for federal financial aid applications, the National Student Loan Data System (NSLDS), and SAT and ACT student test scores.
NPSAS:2000 dropped the parent interview and expanded the sample size to 60,000 students. NPSAS:04 introduced a self-administered web-based student interview option, further increased the sample size to 110,000 students and, for the first time, oversampled undergraduate students in 12 states to permit state-representative estimates for those states. NPSAS:08 retained state-representative oversamples for six states, enlarged the sample size to 130,000 students, and added the National Student Clearinghouse (NSC) as an administrative data source. NPSAS:12, in response to the growing for-profit sector and to ensure reliable estimates at all institution levels, dropped the state-representative samples, but added separate sampling for all levels of the for-profit sector: less-than-2-year, 2-year, and 4-year institutions. In addition, NPSAS:12 was the first cycle to use current-year 12-month institutional enrollment data to ensure more accurate poststratification (weighting) than was achieved using prior-year enrollment data. NPSAS:16 expanded the institution sampling sectors to include a sector for public 4-year institutions that are primarily sub-baccalaureate and added an administrative match to the Veterans Benefits Administration (VBA). Additional details about each of the prior NPSAS studies and related longitudinal studies conducted by NCES are provided at http://nces.ed.gov/surveys/npsas/.
NPSAS:18-Administrative Collection (AC) was the first NPSAS solely reliant on administrative data sources, designed to provide researchers and policymakers with the ability to create national and state-level undergraduate estimates for all 50 states, the District of Columbia, and Puerto Rico (OMB# 1850-0666 v.20-21). Since 1996, NPSAS has been conducted every four years and has included administrative file matching, student records collected from postsecondary institutions, and a student interview. NPSAS:18-AC was the first NPSAS study to be conducted at the midway point in a typical 4-year NPSAS cycle and to not include the student interview.
Two longitudinal studies conducted within the Sample Surveys Division of NCES were designed to address a variety of issues regarding higher education. Based on samples of students enrolled for postsecondary education in a particular year regardless of age, each of these studies incorporates base year data from the cross-sectional NPSAS and extends it through longitudinal follow-up components focusing on first-time students and on recent college graduates in alternate NPSAS survey years: Beginning Postsecondary Students (BPS) and Baccalaureate and Beyond (B&B). The chronology of the previous administrations of the NPSAS study and its associated longitudinal components is presented in table 1.
Table 1. Chronology of NPSAS and its longitudinal components
Base year |
First follow-up |
Second follow-up |
Third follow-up |
NPSAS:90 |
BPS:90/92 |
BPS:90/94 |
— |
NPSAS:93 |
B&B:93/94 |
B&B:93/97 |
B&B:93/03 |
NPSAS:96 |
BPS:96/98 |
BPS:96/01 |
— |
NPSAS:2000 |
B&B:2000/01 |
— |
— |
NPSAS:04 |
BPS:04/06 |
BPS:04/09 |
— |
NPSAS:08 |
B&B:08/09 |
B&B:08/12 |
B&B:08/18 |
NPSAS:12 |
BPS:12/14 |
BPS:12/17 |
— |
NPSAS:16 |
B&B:16/17 |
B&B:16/20 |
B&B:16/26 (anticipated) |
NPSAS:18-AC |
— |
— |
— |
NPSAS:20 |
BPS:20/22 |
BPS:20/25 (anticipated) |
— |
— Not applicable.
NOTE: BPS = Beginning Postsecondary Students; B&B = Baccalaureate and Beyond.
The seven major issues addressed in these Sample Surveys Division studies are:
Undergraduate access/choice of institution;
Persistence;
Progress/curriculum;
Attainment/outcome assessment;
Financial aid and student debt;
Access to graduate programs; and
Benefits of postsecondary education to individuals and society.
This section provides information on the purposes of NPSAS and an overview of the primary research issues it addresses.
The fundamental purpose of NPSAS is to create a research data set that brings together information about a variety of programs for a large sample of undergraduate and graduate students. NPSAS provides the data for comprehensive descriptions of the undergraduate and graduate student populations in terms of their demographic characteristics, academic programs, types of institutions attended, attendance patterns, and employment. Demographic and enrollment data establish the appropriate context that allows researchers and policy analysts to address basic issues about postsecondary affordability and the recipients of student financial assistance. These results are presented in multiple publications.
Ultimately, data collected via NPSAS:20 will make important contributions to studies of postsecondary education policy at the federal and state level. The data can be used to calculate statistics with PowerStats, QuickStats, and TrendStats, web-based software applications available to the public at http://nces.ed.gov/datalab, and to qualified researchers through the IES restricted-use data licensing program (https://nces.ed.gov/pubsearch/licenses.asp).
NCES anticipates distributing data feedback reports to postsecondary institution respondents, state agencies, and associations if the report provides stable estimates. These reports will include data and figures comparing institutional measures from Integrated Postsecondary Education Data System (IPEDS) with estimates from NPSAS:20 by sector at the national level and state level. The reports will underscore the importance of NPSAS data and ‘give back’ to institutions by providing comparative data with their peers.
A second purpose of NPSAS is to gather base-year data on a subset of students who become the sample for a longitudinal study. NPSAS:20 will establish the base year cohort for a BPS study of first-time beginning undergraduate students, with a follow-up survey two years later, in 2022 (BPS:20/22), and an additional follow-up anticipated in 2025. A section of the student interview will capture information about student knowledge, experiences, and perceptions of the costs and benefits of education to support analysis of student choices related to major, persistence, and completion.
A third purpose of NPSAS is to provide a nationally representative sample that can be used to rigorously address fundamental research questions through experimental research methodologies. NCES may expand the use of NPSAS through collaboration with the National Center for Education Research (NCER). NPSAS provides a rich source of data that could be used to support experimental research funded by NCER.
Many of the important questions that NPSAS:20 aims to address are the same as in the past years. College cost increases, net price levels, and increases in student loan debt will continue to be central issues. The NPSAS:20 data will be used to address policy issues related to changes in federal financial aid programs resulting from the anticipated reauthorization of the Higher Education Act. Following are some of the primary research and policy issues that could be addressed using NPSAS:20 data:
(1) Student demographics;
What is the distribution of student enrollment among types of institutions by gender, race/ethnicity, age, dependency, and income?
What types of institutions are serving the largest proportions of low-income, nontraditional, and ethnic minority students?
What proportion of undergraduates are first-generation college students, and what types of institutions are they attending?
What proportion of students are immigrants or children of immigrants, and what types of institutions are they attending?
What proportion of students enrolled in postsecondary education are active military or veterans, and what types of institutions do they attend?
(2) Academic preparation and programs;
What proportion of college students have taken remedial courses?
What types of students are enrolled in vocational certificate, associate’s degree, and bachelor’s degree programs, and what are their fields of study?
(3) Financial aid;
What proportion of students need financial aid, and what is the average amount of need by income?
What proportion of students has remaining need beyond what they receive in financial aid, and what is the average amount of unmet need?
What proportion of students receive federal Pell grants, and where do they attend college?
What proportion of students are receiving aid from states, institutions, employers, and private sources, and what is the average amount received?
What proportion of students are receiving need-based or merit-based aid?
How does the amount and type of aid vary by dependency and income level?
What is the ratio of federal to nonfederal aid at various types of institutions?
What is the ratio of grants to loans at various types of institutions?
What proportion of students receive veterans and other Department of Defense benefits, and how much do they receive?
How has the incidence and average amount of veterans’ benefits changed since the enactment of the Post-9/11 GI Bill (P.L. 110-252)?
How has the number and proportion of nonveterans receiving veterans’ benefits as dependents of veterans changed since enactment of the Post-9/11 GI Bill (P.L. 110-252)?
What types of institutions enroll the highest proportions of active-duty military personnel, veterans, and recipients of veterans’ benefits?
(4) Price of attendance;
What are the differences in the average tuition and total price of attendance by type of institution and among students by dependency, income, and full-time or part-time attendance status?
What is the average net price of attendance (student budget minus financial aid) at various income levels at different types of institutions?
(5) Student borrowing;
What are the differences in the percentage of students borrowing and the average amounts borrowed through the federal student loan programs by institution type, attendance status, class level, and income?
What proportion of students borrow the maximum Direct (Stafford) Loan amounts?
What is the difference in the proportion of students receiving subsidized or unsubsidized Direct (Stafford) Loans by dependency and income level?
What proportion of graduate students borrow and at what rate do they use Graduate PLUS loans to fund their education?
What is the average cumulative debt of students by class level, especially among graduating college seniors?
What is the average cumulative debt of graduate students and what portion of that debt was incurred in graduate school?
What proportion of students borrow private loans, in what amount, and how does this borrowing vary by institution type?
(6) Student employment;
What proportion of students engage in paid work while enrolled and what are the average hours per week they work?
What is the average amount earned from work while enrolled?
What proportion of students is employed by their institution in work-study and graduate assistantships as compared with other types of employment?
(7) Sources of funds;
What types of financial support are dependent students receiving from their parents?
Answers to these and other questions are vital if policymakers at the local, state, and national levels are to respond adequately to the changing environment of postsecondary education. Since inception, the NPSAS, BPS, and B&B series have resulted in numerous NCES publications addressing these issues. These reports can be found at: https://nces.ed.gov/pubsearch/.
Enrollment lists will be provided on the Postsecondary Data Portal (PDP) website. The PDP website is used across NCES institution data collections. Section B.3 of the Supporting Statement Part B includes information about how the website is used for multiple studies.
For NPSAS:20, postsecondary institutions will be offered three modes for providing data: entering data directly using a web-based data entry interface (web mode), completing a pre-formatted Excel workbook template (Excel mode), and creating data files in comma separated value format (CSV mode). These data entry modes are also described in section B.3 of Part B.
The PDP website for data collection will reside on NCES’s Secure Sockets Layer (SSL)-encrypted servers. On a nightly basis, the data collection contractor will download data in batches to their Enhanced Security Network (ESN) via a secure web service. Once in the ESN, data will be cleaned and undergo quality analysis. SSL protocol is used to encrypt the data transmitted over the Internet, and data entry modules are password protected. Separate login credentials are created for each user at the participating institution. The forms that gather data on this website will require session cookies to run in accordance with the U.S. Department of Education's privacy policy for the use of cookies. The most recent versions of Microsoft Internet Explorer, Google Chrome, and Mozilla Firefox allow for rejecting all cookies other than those required for session tracking.
Efforts to identify duplication have included NCES consultations with other federal offices, such as the U.S. Department of Education’s Office of Postsecondary Education; the Office of Planning, Evaluation, and Policy Development; and other agencies, such as the Government Accountability Office; the Congressional Budget Office (CBO); and the Office of Management and Budget (OMB). In addition, NCES collaborates with the National Center for Science and Engineering Statistics (NCSES) at the National Science Foundation (NSF) to ensure that each unit is kept up to date on each other’s studies pertaining to postsecondary students and institutions. NCES and NSF meet on a regular basis to cover topical issues relevant to both offices, and each has staff serving on study TRPs. NCES routinely consults with nonfederal associations, such as the American Council on Education, the Career Education Colleges and Universities, the National Association of Student Financial Aid Administrators, the National Association of Independent Colleges and Universities, the Council of Graduate Schools, the Institute for Higher Education Policy, the State Higher Education Executive Officers Association, and the National Association of State Student Grant and Aid Programs to confirm that data collected through NPSAS are not available from any other sources. NCES also consults with academic researchers, several of whom attend the NPSAS TRP meetings. Beyond identification of duplication, these consultations provide methodological insights from the results of similar and related studies conducted by NCES, other federal agencies, and nonfederal sources. The consultations also assure that data collected through NPSAS will meet the needs of the federal government and relevant organizations. No studies in the United States singularly duplicate the data produced by NPSAS.
The burden associated with enrollment list collection is relatively low for all institutions, including small businesses that may be contacted as part of the NPSAS:20 full scale (for-profit schools and other small public and private schools). NPSAS:20 is asking for a readily-available set of variables on the enrollment lists, and institutions will be offered alternative methods of providing requested data, including uploading to a secure website or emailing encrypted list files. We will attempt to minimize the intrusion and burden to such schools by working closely with a school-appointed coordinator before the data collection effort to identify the sources of information within the school and the format in which records are kept. We have also discussed enrollment list variables with the technical review panel to ensure that the request is minimally burdensome and consistent with typical recordkeeping at postsecondary institutions. In addition, to facilitate participation of institutions in Puerto Rico, Spanish translations of letters to the chief administrator and coordinator as well as the study brochure and the Quick Guide to NPSAS:20 (appendix D) will be sent to institution staff at institutions in Puerto Rico.
Large-scale and rapid changes in federal policy concerning postsecondary student aid necessitate frequent studies that provide accurate and up-to-date information necessary for informed decision making. More federal policymaking is occurring outside the Higher Education Act renewal process through regulation, the budget appropriation process, and Reconciliation. This has resulted in more changes to the Federal Student Aid (FSA) programs compared to when the Higher Education Act was reauthorized on a set schedule. From year to year, eligibility restrictions change, the FAFSA changes (e.g., simplification and prior-prior year income), size of grant and loan amounts fluctuate, and the balance between various aid options changes dramatically. Because these changes affect students’ ability to finance postsecondary education and the level of debt students accumulate, frequent data collections are necessary. Moreover, the dynamic nature of the postsecondary environment itself calls for more frequent data collection. For example, notable closures among for-profit institutions have consequences for the postsecondary climate and student financing, as do changes in private-sector lending, increases in tuition and fees, and changes in federal student aid policies. Effects of these changes on federal policy and postsecondary education participation create an opportunity, as well as a need, for frequent monitoring on a regular basis.
No special circumstances of data collection are anticipated.
Recognizing the significance of NPSAS data collection, several strategies have been incorporated into the project work plan that allow for the critical review and acquisition of comments relating to project activities, interim and final products, and projected and actual outcomes. These strategies include consultations with persons and organizations both internal and external to NCES, the U.S. Department of Education, and the federal government.
Previous NPSAS implementations have benefited from a TRP composed of staff from several offices in the Department of Education; representatives of NSF, OMB, and CBO; and nonfederal members who are considered experts in postsecondary education issues, including financial aid (a list of the TRP members is provided in appendix A). A TRP meeting, which included a web conference with state-based agency representatives from across the country, was held in November 2018 to inform the NPSAS:20 data collection activities, specifically the student enrollment list and student records collection from institutions. Another TRP will be held in May 2019 to discuss student interview data collection activities.
Institutions may require reimbursement for the cost of time spent preparing and providing enrollment lists and student records. Expenses will be reimbursed to the extent that they are reasonable and properly documented. Mailings to institutions may include pens, notepads, or other small courtesy items bearing a logo related to the study or NCES, which will serve as reminders to institution staff and provide tokens of appreciation for their efforts. These items may also be distributed at conferences attended by potential NPSAS participants.
NCES assures participating individuals that all information collected under NPSAS:20 may be used only for statistical purposes and may not be disclosed, or used, in identifiable form for any other purpose except as required by law (20 U.S.C. §9573 and 6 U.S.C. §151).
The primary contractor for this study is RTI International. Confidentiality and data security protection procedures have been put in place for NPSAS:20 to ensure that the contractor and its subcontractors comply with all privacy requirements, including:
The statement of work of this contract;
Family Educational Rights and Privacy Act (FERPA) of 1974 (20 U.S.C. §1232(g));
Privacy Act of 1974 (5 U.S.C. §552a);
Privacy Act Regulations (34 CFR Part 5b);
Computer Security Act of 1987;
U.S.A. Patriot Act of 2001 (P.L. 107-56);
Education Sciences Reform Act of 2002 (ESRA 2002, 20 U.S.C. §9573);
Cybersecurity Enhancement Act of 2015 (6 U.S.C. §151);
Foundations of Evidence-Based Policymaking Act of 2018, Title III, Part B, Confidential Information Protection
The U.S. Department of Education General Handbook for Information Technology Security General Support Systems and Major Applications Inventory Procedures (March 2005);
The U.S. Department of Education Incident Handling Procedures (February 2009);
The U.S. Department of Education, ACS Directive OM: 5-101, Contractor Employee Personnel Security Screenings;
NCES Statistical Standards; and
All new legislation that impacts the data collected through the contract for this study.
Furthermore, the contractor will comply with the Department of Education’s IT security policy requirements as set forth in the Handbook for Information Assurance Security Policy and related procedures and guidance, as well as IT security requirements in the Federal Information Security Management Act (FISMA), Federal Information Processing Standards (FIPS) publications, Office of Management and Budget (OMB) Circulars, and the National Institute of Standards and Technology (NIST) standards and guidance. All data products and publications will also adhere to the revised NCES Statistical Standards, as described at the website: http://nces.ed.gov/statprog/2012/.
By law (20 U.S.C. §9573), a violation of the confidentiality restrictions is a felony, punishable by imprisonment of up to 5 years and/or a fine of up to $250,000. The NPSAS:20 procedures for maintaining confidentiality include notarized nondisclosure affidavits obtained from all personnel who will have access to individual identifiers; personnel training regarding the meaning of confidentiality; controlled and protected access to computer files; built-in safeguards concerning status monitoring and receipt control systems; and a secure, staffed, in-house computing facility. NPSAS:20 follows detailed guidelines for securing sensitive project data, including, but not limited to: physical/environment protections, building access controls, system access controls, system login restrictions, user identification and authorization procedures, encryption, and project file storage/archiving/destruction.
Additionally, the contractor will take security measures to protect the web data collection application from unauthorized access. The web server will include an SSL certificate and will be configured to force encrypted data transmission over the Internet. All files uploaded to the website will be stored in a secure project folder that is accessible and visible to authorized project staff only. To access restricted pages containing confidential information, website users will be required to log in by entering an assigned ID number and password. Through the website, the primary coordinators at the institution will be able to use a “Manage Users” link, available only to them, to add and delete user accounts for other staff at the same institution. The new users will be assigned a temporary password, which they will be required to change upon logging in to the website for the first time.
Security measures have been put in place to protect data during file matching procedures described in section A.3 of this document. NCES has a secure data transfer system, which uses SSL technology, allowing the transfer of encrypted data over the Internet. The IES File Transfer System will be used for all administrative data sources that do not have their own secure file transfers systems All data transfers will be encrypted.
The Department has established a policy regarding the personnel security screening requirements for all contractor employees and their subcontractors. The contractor must comply with these personnel security screening requirements throughout the life of the contract, including several requirements that the contractor must meet for each employee working on the contract for 30 days or more. Among these requirements are that each person working on the contract must be assigned a position risk level. The risk levels are high, moderate, and low based upon the level of harm that a person in the position can cause to the Department’s interests. Each person working on the contract must complete the requirements for a “Contractor Security Screening.” Depending on the risk level assigned to each person’s position, a follow-up background investigation by the Department will occur.
NPSAS:20 and other NCES postsecondary studies include data linkages with many existing sources of valuable data, including Department of Education’s (ED) CPS for FAFSA data, NSLDS, and NSC. These NCES studies also obtain data from postsecondary institution student records, information on military service records from VBA, and admissions test scores from ACT and The College Board. Many of these administrative data matches are not guaranteed and will require separate Memorandums of Understanding, Agreements, or Contracts with the entities responsible for the individual data elements.
Regarding file matching with administrative sources, 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 NPSAS:20 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.”
NPSAS:20 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.”
Additionally, the study, including the administrative data linkage, qualifies for a 45 CFR Part 46 waiver of consent based on the following factors:
There is minimal risk to the participants. There is no physical risk and only minimal risk associated with linkage of data to sample members. The public-use and restricted-use data, prepared as part of the contract with the data collection contractor, will not include Social Security Numbers (SSNs) or other extremely sensitive Personally Identifiable Information (e.g., name, birthdate, etc.) even though these data elements are used for the linkage. Data will undergo disclosure avoidance analysis and disclosure treatment steps to further reduce the risk.
The waiver will not affect the rights and welfare of sampled students. Public-use and restricted-use data are only used for research purposes and lack direct individually-identifying information. The data are further protected through disclosure avoidance procedures approved by the NCES Disclosure Review Board.
The study cannot be conducted practicably without the waiver. Data will be collected from postsecondary institutions, and there will be no direct contact with sampled students. To obtain written consent from sampled students, multiple forms would have to be sent to them with multiple follow-up telephone and in-person visits. This process would add weeks to the data collection process and is not feasible from a time standpoint. Additionally, the value of these data would be jeopardized from a nonresponse bias perspective.
The following language will be included, as appropriate, in respondent contact materials and on data collection instruments:
NCES is authorized to conduct the 2019-20 National Postsecondary Student Aid Study (NPSAS:20) by the Education Sciences Reform Act of 2002 (ESRA 2002, 20 U.S.C. §9543) and the Higher Education Opportunity Act of 2008 (HEOA 2008, 20 U.S.C. §1015).
All of the information [you provide/provided by individuals or institutions] may be used only for statistical purposes and may not be disclosed, or used, in identifiable form for any other purpose except as required by law (20 U.S.C. §9573 and 6 U.S.C. §151).
The Family Educational Rights and Privacy Act of 1974 (FERPA, 20 U.S.C. §1232g) allows for the release of institution record information to the Secretary of Education or her agent without prior consent of survey members (34 CFR §§ 99.31[a][3] and 99.35).
According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The valid OMB control number for this voluntary information collection is 1850-0666. The time required to complete this information collection is estimated to average approximately 5 hours per response, including the time to review instructions, search existing data sources, gather the data needed, and complete and review the information collection. If you have any comments concerning the accuracy of the time estimate, suggestions for improving this information collection, or any comments or concerns regarding the status of your individual submission of these data, please write directly to: Postsecondary Data Portal studies, ATTN: [NCES PDP Project Officer Name], National Center for Education Statistics, PCP, 550 12th St., SW, 4th floor, Washington, DC 20202.
Institutions will be asked to provide personally-identifying information for students on the enrollment lists (including name, contacting information, SSN, and date of birth (DOB)). Although considered sensitive, items collected on the enrollment lists will facilitate 1) selection of the student sample, 2) initial tracing and locating activities, and 3) ongoing follow up with the first-time beginning student cohort as part of BPS:20. Immediately after the student sample is selected, the SSNs for non-selected students will be securely discarded.
Table 2 provides the projected estimates for response burden for NPSAS:20, which are based on experiences from prior rounds of NPSAS. The response time for participating institutions will vary based on how institutions keep their records and how easily they can extract the requested information. The NPSAS:20 institution data collection includes four activities:
responding to eligibility-screening calls, which will be made only to sampled institutions for whom contact information could not be located through other sources (we estimate 853 institutions to fulfill this criteria in NPSAS:20, based on our experience in prior administrations of NPSAS);
completing the Institution Registration Page (IRP), which collects basic information about institutional characteristics and term structure (we estimate that of the 3,106 institutions sampled, 99 percent will be eligible for NPSAS, based on our experience in prior administrations of NPSAS);
providing electronic lists of all students enrolled during the academic year either by uploading a file to the secure PDP website or e-mailing an appropriately encrypted file directly to the data collection contractor. (Based on NPSAS:16 and NPSAS:18-AC results, we expect that most NPSAS:20 enrollment lists will be uploaded to the project website, and very few enrollment lists will be sent via email); and
providing student records data for the institution’s sampled students (the details of procedures and materials and the burden request for this activity will be included in the student data collection submission in the summer of 2019).
The estimated burden for each of these activities is included in table 2; the sample sizes shown are discussed in Part B of this package. Using time-burden data for similar institutional data collection tasks, we estimate the average burden per institution to be approximately 5 hours for preparation of the enrollment list (we anticipate the later student record collection will on average require approximately 30 hours). Estimating an average hourly rate of $41.591 for the institutional staff, the 13,577 total burden hours translate to an estimated respondent burden time cost of approximately $564,668.
Table 2. Average estimated burden to institution respondents for the NPSAS:20 data collection
Data collection activity |
Sample |
Expected eligible |
Expected response rate (percent) |
Expected number of respondents* |
Expected number of responses |
Average time burden per response (mins) |
Total time burden (hours) |
Institutional collection |
|
|
|
|
|
|
|
Eligibility-screening calls1 |
853 |
845 |
100 |
845 |
845 |
5 |
71 |
Institution registration page |
3,106 |
3,075 |
85 |
2,614 |
2,614 |
10 |
436 |
Institutional enrollment lists |
3,106 |
3,075 |
85 |
2,614 |
2,614 |
300 |
13,070 |
Institution student records |
|
|
|
|
|
|
|
Student record collection1 |
2,614 |
2,614 |
93 |
2,431 |
2,431 |
1,800 |
72,930 |
Total |
|
|
|
2,614 |
6,073 |
|
13,577 |
* Unduplicated count of respondents.
1 “Sample” is the number of institutions that provided enrollment lists for student sampling. Gray font depicts activities for which burden is not being requested in this submission and thus not included in the total (it will be requested in the student data collection submission in the summer of 2019).
There are no additional costs to the respondents.
The total cost to the federal government for this administration of the NPSAS:20 full-scale study is $15,148,500, of which $765,320 is for institution contacting and enrollment list collection requested in this submission. A summary of costs is shown in table 3. Included in the estimates are staff time, reproduction, postage, and telephone costs associated with the data collection for which clearance is requested.
Table 3. Costs to NCES for the NPSAS:20 full-scale study
NPSAS:20 main study implementation |
Costs to NCES |
Total |
$15,148,500 |
NCES Salaries and expenses |
$330,000 |
Contract costs |
$14,818,500 |
Instrumentation and materials |
$1,468,100 |
Data collection |
$9,255,600 |
Systems and data processing |
$4,094,800 |
The decrease in the total burden hours from the last approved is due to the fact that the last submission was for the NPSAS:18-AC full-scale data collection which in addition to similar activities as those described here, also included student records collection, an activity that is not included in this request (to be requested in the student data collection submission in the summer of 2019).
The operational schedule for the NPSAS:20 full-scale study is shown in table 4. The following NPSAS:20 reports, publications, and other public information releases are planned:
descriptive summaries of significant findings for dissemination to a broad audience;
detailed data file documentation describing all aspects of the full-scale study design and data collection procedures;
complete data files and documentation for research data users in the form of both a restricted-use file; QuickStats, a public-use data analysis system in which users create their own tables and charts using predefined categories from a subset of variables; and PowerStats, a public-use data analysis system in which users create their own tables and charts using all of the variables, in addition to conducting regression analysis, and which is the basis for TrendStats that allows users to analyze data across NPSAS administrations with optional automatic inflation adjustments for dollar values (NCES may release a Public Use microdata file if it is technically feasible after disclosure review); and
special tabulations of issues of interest to the higher education community, as determined by NCES.
Table 4. Operational schedule for NPSAS:20
NPSAS:20 activity |
Start date |
End date |
Full-scale study |
|
|
Contacts with institutions |
Oct. 16, 2019 |
Nov. 20, 2020 |
Calibration sample |
|
|
Enrollment list collection - calibration sample |
Nov. 7, 2019 |
Dec. 31, 2019 |
Select student sample |
Nov. 18, 2019 |
Feb. 23, 2020 |
Self-administered web-based data collection |
Jan. 13, 2020 |
Mar. 2, 2020 |
Conduct telephone interviews of students |
Jan. 13, 2020 |
Mar. 2, 2020 |
Main Sample |
|
|
Enrollment list collection - main sample |
Jan. 10, 2020 |
Jul. 10, 2020 |
Select student sample |
Jan. 21, 2020 |
Jul. 20, 2020 |
Collect student data from institutional records |
Mar. 2, 2020 |
Nov. 13, 2020 |
Self-administered web-based data collection |
Apr. 13, 2020 |
Nov. 20, 2020 |
Conduct telephone interviews of students |
Apr. 13, 2020 |
Nov. 20, 2020 |
Process data, construct data files |
Jan. 13, 2020 |
Dec. 10, 2020 |
Prepare/update data collection reports |
Jan. 13, 2020 |
Dec. 18, 2020 |
The expiration date for OMB approval of the information collection will be displayed on data collection instruments and materials. No special exception is being requested.
There are no exceptions to the certification statement identified in the Certification for Paperwork Reduction Act Submissions of OMB Form 83-I.
1 The hourly rate ($41.59) was obtained using the hourly mean wage of operations research analysts in the May 2017 National Occupational and Employment Wage Estimates sponsored by the Bureau of Labor Statistics (BLS). Source: BLS Occupation Employment Statistics, http://data.bls.gov/oes/ data type: Occupation codes: Operations Research Analysts (15-2031); accessed on March 1, 2019.
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