Justification for Submission

DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

JUSTIFICATION FOR SUBMISSION UNDER THE
“DOI PROGRAMMATIC CLEARANCE FOR
CUSTOMER SATISFACTION SURVEYS”

See Page 5 for Instructions on Completing This Form
1. Bureau/Office

2. Date Submitted

Bureau of Indian Education, Division of Performance and Accountability

09/29/2021

3. Survey Title

Survey of Parent Involvement in Special Education
4. Abstract (Not to exceed 150 words)

In accordance with the Paperwork Reduction Act of 1995, we, the Bureau of Indian Education (BIE) are
proposing to renew an information collection with revisions.
The Individuals with Disabilities Education Act (IDEA) requires each state to develop a State Performance
Plan/Annual Performance Report (SPP/APR) under 34 CFR § 300.601 - State performance plans and
data collection. The SPP/APR evaluates the state’s efforts to implement the requirements and purposes
of the IDEA and describes how the state will improve its implementation. The SPP/APRs include
indicators that measure child and family outcomes and other indicators that measure compliance with the
requirements of the IDEA.
The SPP/APR indicator B8 measures how parents with a child receiving special education services report
how schools facilitated their involvement as a means of improving services and results for their children
with disabilities. (20 U.S.C. 1416(a)(3)(A)). States collect these data via annual surveys from parents of
students with disabilities enrolled in BIE-funded schools. The BIE collects and summarizes these parent
survey data and reports these data against the targets established in its APR.
In this revision, BIE proposes to reduce the form length. BIE estimates the reduced/streamlined form will
result in a material reduction for the information collection’s time per response by respondents.
5. Bureau/Office Point-of-Contact Information
First Name

Last Name

Eugene

Thompson

Title

Bureau/Office

Supervisory Education Specialist

Bureau of Indian Education, Division of Performance and Accountability

Mailing Address

City

1009 Indian School Rd., NW, Suite 149

Albuquerque

Phone
202-860-5812

Work
Cell

Fax

Last Name

Title

Bureau/Office

Mailing Address

City

Work
Cell

Fax

NM

Zip Code
87104

Email
[email protected]

6. Principal Investigation (PI) Point-of-Contact Information
First Name
Same as #5

Phone

State

State

Zip Code

Email

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

7. Name of Program or Office Conducting Survey

Bureau of Indian Education, Division of Performance and Accountability
8. Description of Customers and Services Provided

Customers: Parents of children with disabilities enrolled in BIE-funded schools.
Services: Students with disabilities are provided special education and related services as identified in their
Individualized Education Programs (IEPs)
9. Survey Dates
(mm/dd/yyyy)

02/01/2022

(mm/dd/yyyy)
02/01/2025

to

10. Type of Information Collection Instrument (Check ALL that Apply)
Intercept

Telephone

Mail

Web-based

Comment Cards

Other: (Explain) Paper copy
Focus Groups
11. Survey Development (Who assisted in survey content development statistics? Was the survey pretested? How did you
integrate improvements? Which of the six topic areas did you address?)

Staff from the Bureau of Indian Education, Division of Performance and Accountability collect and analyze the data for the APR.
The original survey was developed by an Office of Special Education Programs (OSEP)-sponsored center. Improvements to the
survey were done by prioritizing the survey questions to best inform the the SPP/APR indicator B8 measures.
12. Survey Methodology (Use as much space as needed; if necessary, include additional explanation on separate page.)
12A. Respondent Universe
All parents, guardians or primary caretakers of students with disabilities (students with an Individual Education Plan in place) who are attending BIE-funded schools are potential
responders to this survey. Each school will be requested to work with all parents in this category with students attending their school for complete the survey in electronic form or
paper version.

12B. Sampling Plan/Procedure

It is a census survey (this survey does not use a sample).
12C. Instrument Administration
The manners of administration will be electronic or face-to-face. Each school will be requested to work with the parents of students with disabilities to provide access to, and
completion of, the paper version of the survey or online on the BIE website. Interpreters will be available to orally interpret any part or all of the survey in a language the parents
understand for both face-to-face and online completion of surveys.

12D. Expected Response Rate and Confidence Levels

There are approximately 5,000 students with disabilities (SWD) receiving their education in BIE funded schools at
any given time. It is anticipated that 60% will participate in the survey (3,000 parents).
12E. Strategies for dealing with potential non-response bias
Increasing participation has the potential to increase representativeness. Strategies to increase participation that BIE/DPA will employ include publicizing the survey on school
websites, BIE websites, and offering an on-line version of the survey alongside the traditional paper version. BIE will also share the survey and results of the survey with teachers and
school leaders to encourage them to promote parent participation and work with parent groups to encourage participation.

12F. Description of any pre-testing and peer review of the methods and/or instrument (recommended)
BIE-DPA proposes to utilize the paper-copy form and on-line link at the BIE website for the completion and collection of parent survey data. BIE school administrative
staff can identify and provide access to parents of students with disabilities that need access to the survey (in paper form or online link at the BIE website).

13. Burden Hours Calculations
Category of Respondent

Number of Annual
Respondents

Number of
Responses Each

Total Annual
Responses

Time per
Response

0

Initial Contact
Completion of Survey Instrument

Total Burden
Hours

3,000

Totals: 3,000

1

3,000
3,000

10 min

500
500

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

14. Federal Enterprise Architecture (FEA) Business Reference Model (Check only one “Line of Business” and one
“Subfunction.” Refer to OMB guidance “FEA Consolidated Reference Model Document Version 2.3”)
Line of Business
Subfunction
Line of Business
Subfunction
Community and
Social Services
Defense and
National Security
Economic
Development

Correctional
Activities
Disaster
Management

(Select One)

(Select One)

Education

Elementary, Secondary, and Vocational Educ

Energy

(Select One)

Environmental
Management

(Select One)

General Science
and Innovation

(Select One)

Health

(Select One)

Homeland Security

(Select One)

(Select One)

■

(Select One)

(Select One)

Income Security

(Select One)

Intelligence
Operations

(Select One)

(Select One)

Law Enforcement

(Select One)

International Affairs
and Commerce
Litigation and
Judicial Activities

Natural Resources

(Select One)

Transportation

(Select One)

Workforce
Management
15. Reporting Plan

(Select One)

(Select One)

Summary of the data will be used to report in the BIE Annual Performance Report to OSEP, on a yearly basis, and will be made available to the public on BIE’s website per OSEP’s
requirement. The information will also be provided to each school so they may review the information with the school community, including parents that participated in the survey.
Information will be used to improve parent involvement and how schools facilitate the involvement of parents in the educational programming for their child with a disability.

16. Justification, Purpose, and Use
16A. Survey Justification and Purpose
The survey referenced in this document will be used to respond to Indicator 8 of the State Performance Plan (SPP) as required by the Office of Special Education (OSEP). PL 108-446 Individuals with Disabilities
Education Act (IDEA) requires the submission of specific data as a requisite to the receipt of federal funding to support services for students with disabilities attending BIE funded schools. Indicator 8 of the SPP
addresses parental involvement and requires reporting the percent of parents who indicate their child’s school facilitated parent involvement which resulted in improved educational results for the child.

16B. Survey Goals

The survey goal is to collect data on parents’ perception of how BIE-funded schools facilitated their
involvement their child’s education program.
16C. Utility to Managers
The BIE/DPA office will use these data to a) report on this requirement to OSEP, b) better understand the issue of parent involvement in the schools, parent satisfaction levels, opportunities for improving services and
plan future system-wide activities to address areas of need, and c) understand which Bureau funded schools will benefit from technical assistance and support. At the school level a) there will a better understanding
on how the parents of students with disabilities believe their school is involving them in a meaningful way in the educational planning for their child, b) parents will have been given the opportunity to provide input to the
school, and c) the school can address areas identified as a need by the surveys completed at the school. Managers in both instances described above would be the education administrators.

16D. How will the results of the survey be analyzed and used?
Per OSEP’s guidance on the SPP/APR indicator B8 (20 U.S.C. 1416(a)(3)(A)), the results will be analyzed using descriptive statistics to calculate the percent of parents who, by agreeing with the aggregate of the
survey statements report schools facilitated their involvement in their child’s education as a means of improving services and results for children with disabilities. The descriptive analysis also includes calculating the
response rate and the representativeness of respondents by disability category within the population. Besides meeting a requirement of IDEA, the results of the survey will be used according to what was described in
item 16C above.

16E. How will the data be tabulated? How What Statistical Techniques will be used to generalize the results to the entire
customer population? How will limitations on use of data be handled? If the survey results in a lower than anticipated
response rate, how will you address this when reporting the results? (Use as much space as needed; if necessary, include
additional explanation on separate page.)
The data will be collected and tabulated using descriptive statistics to organize the data into a summary statement that meets the SPP/APR indicator B8 (20 U.S.C. 1416(a)(3)(A)). The response rate will be analyzed with respect
to previous years and efforts will be used to improve response rates (as described in 12E) and potential causes of an eventual lower response rate will investigated and described as part of the analysis. Demographics such as
grade and type of disability of respondents will be analyzed to measure representativeness of the respondents and will be reported as part of the survey results, indicating groups who may have been under or over represented.

16F. Is this survey intended to measure a Government Performance and Results Act (GPRA) performance measure? If
yes, please include an excerpt from the appropriate document. (Use as much space as needed; if necessary, include additional
explanation on separate page.)
This survey is intended to measure an SPP indicator for reporting to OSEP. See indicator as follows: (The indicator is taken directly from the OSEP SPP guidance.)
State Performance Plan / Annual Performance Report
Indicator 8: Percent of parents with a child receiving special education services who report that schools facilitated parent involvement as a means of improving services and results for children with disabilities. (20 U.S.C. 1416(a)(3)(A))
Measurement: Percent = [(number of respondent parents who report schools facilitated parent involvement as a means of improving services and results for children with disabilities) divided by the (total # of respondent parents of children with disabilities)] times 100.

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

17. Federal Cost: (Consult your Bureau/Office Information Collection Clearance Officer for assistance, if necessary)
The estimated annual cost to the Federal government is $ 23,555.00

, based on: (provide details below)

Expecting 3,000 surveys processed out of 5,000 surveys submitted, we estimate 583 hours as initial contact on the 5,000 parent population, 50 hours entering
data on the 3,000 surveys (1 minute per survey), and 40 hours performing the analysis. At an estimated $35 hourly rate, the estimated annual cost will be
$23,555. Please note this activity is embedded on BIE/DPA's staff job description in their general supervision role under Section 616 of IDEA.

Sample Response:
“If we receive 20 submissions and it takes 30 minutes to process and implement each one, then the total burden is $322.40
assuming a GS-7 step 5 is processing the submissions. This custom form is a tool meant to accept submissions in a standard format
rather than through the freeform submissions that would otherwise come in by personal email. The existence of this form actually
saves the government money by standardizing submissions and decreasing the workload of processing each one.”
18. The survey methodology presented in form DI-4010 includes a specific description of:
The respondent universe,
The sampling plan and all sampling procedures, including how respondents will be selected,
How the instrument will be administered,
Expected response rate and confidence levels,
Strategies for dealing with potential non-response bias,
A description of any pre-testing and peer review of the methods and/or the instrument is highly recommended,
The burden hours reported in the Justification include the number of burden hours associated with the initial contact of all
individuals in the sample (i.e., including refusals), if applicable, and the number of burden hours associated with individuals
expected to complete the survey instrument, and
The package is properly formatted (using MS Word) and submitted to the Office of Policy Analysis (through the Bureau/Office
Information Collection Clearance Officer).
19. The approval package includes:
A completed and signed Form DI-4010, Generic Clearance for Customer Satisfaction Surveys.
A copy of the survey instrument.
Other supporting materials, such as:
• Cover letters to accompany mail-back questionnaires,
• Introductory scripts for initial contact of respondents,
• Necessary Paperwork Reduction Act and Estimated Burden compliance language, and/or
• Follow-up letters/reminders sent to respondents.
20. Checklist for Submitting a Request to Use DOI Programmatic Clearance for Customer Satisfaction Surveys
All questions in the survey instrument are within the scope of one of the DOI Programmatic Clearance for Customer
Satisfaction Surveys topic areas.
A qualified statistician has reviewed and approved your request (see question 21A).
Your Bureau/Office Information Collection Clearance Officer receives your package for review/approval at least 75 days
prior to the first day the PI wishes to administer the survey to the public.
21. Required Certifications for Submission Under OMB Control Number 1040-0001
Certification is required to submit a collection of information for approval under the DOI Programmatic Clearance for Customer
Satisfaction Surveys. If the collection does not satisfy the requirements of the Programmatic Clearance, you should follow the
regular PRA clearance procedures described in 5 CFR 1320.
21A. Bureau/Office Statistician
Signature
Date
Recommend

Not Recommended

21B. Bureau/Office Program or Subgroup

Bureau/Office Point-of-Contact

Title (Please be specific)

Signature

EUGENE THOMPSON

Date
Digitally signed by EUGENE THOMPSON
Date: 2021.10.05 14:24:47 -06'00'

FOR PROGRAM USE ONLY
Required certifications: The information collection requested by this submission meets the requirements of OMB Control No. 1040-0001

Bureau/Office ICCO
Recommend

Signature
Not Recommended

DOI Office of Policy Analysis
Recommend

Signature

9/30/21
Date

Not Recommended

DOI PRA Program Lead
Approved

STEVEN MULLEN

Date
Digitally signed by STEVEN MULLEN
Date: 2021.09.30 22:45:25 -04'00'

Not Approved

DOI Tracking No.

2021-CS1-BIA

Signature

JEFFREY PARRILLO

Date
Digitally signed by JEFFREY PARRILLO
Date: 2021.10.22 09:39:03 -04'00'

10/22/21

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

Instructions for Completing Form DI-4010,
Justification for Submission Under the
“DOI Programmatic Clearance for Customer Satisfaction Surveys”
OMB Control Number 1040-0001
1.

Bureau/Office: Insert the name of the bureau/office conducting the survey.

2.

Date Submitted: Date you submit the package to the Bureau/Office Information Collection Clearance Officer (ICCO) for review.

3.

Survey Title: Insert title for the proposed survey.

4.

Abstract: Summarize the proposed study with an abstract not to exceed 150 words.

5.

Bureau/Office Point of Contact Information: Complete the bureau/office contact information. PPA will communicate with the
point of contact listed here throughout the entire approval process.

6.

Principal Investigator (PI) Conducting the Survey: Complete information about the PI who will be conducting the survey, if
different from Point of Contact listed in #4. Otherwise note: Same as #4.

7.

Name of Program Office Conducting Survey: Provide the name of the bureau program, office, or organizational unit conducting
the survey.

8.

Description of Customers and Services Provided: Provide a brief description of the customers you will survey, the services
provided by the program conducting the survey, and customers receive these services.

9.

Survey Dates: List the time-period in which you will conduct the survey, including specific starting and ending dates. The starting
date should be at least 75 days after the date you submit the package to your bureau/office Information Collection Clearance
Officer (ICCO).

10. Type of Information Collection Instrument: Check the type(s) of information collection instrument(s) you will use. If other,
please explain.
11. Survey Development: Explain how the survey was developed. With whom did you consult during the development of the survey
on content? On statistics? Did you pretest the survey? What actions did you take to improve the survey? What suggestions did
you receive for improving the survey? Which of the six topic areas will the collection address? (Note: A description of any pretesting and peer review of the methods and/or instrument is highly recommended.)
12. Survey Methodology: Explain how you will conduct the survey. Provide a description of the survey methodology including:
•
Question 12A – The respondent universe,
•
Question 12B – The sampling plan and all sampling procedures;
•
Question 12C – How the instrument will be administered;
•
Question 12D – Expected response rate and confidence levels;
•
Question 12E – Strategies for dealing with potential non-response bias; and,
•
Question 12A – Description of any pre-testing and peer review of the methods and/or instrument (recommended, but not
required).
Note: Web-based surveys are not an acceptable method of sampling a broad population. Web-based surveys must be limited to
services provided by the web site.
13. Burden Hours Calculations: Provide an estimated total of the following for each category – initial contact and completion of
survey instrument:
•
Number of annual respondents – Enter the number of unique respondents who will complete the information collection;
•
Number of responses per respondent – Enter the total number of responses per unique respondent;
•
Total annual responses – Enter the number of unique respondents multiplied by the total number of responses each;
•
Time per response – Estimate the time to complete the initial contact and the time to complete the survey instrument (in
minutes), and
•
Total burden hours –The total burden hours should account for the amount of time required to instruct the respondents in
completing the survey, and the amount of time required for the respondent to complete the survey.
14. Federal Enterprise Architecture (FEA) Business Reference Model: Using the drop-down menus provided, select ONE “Line of
Business” and ONE corresponding Subfunction that most accurately describes your information collection.
15. Reporting Plan: Provide a brief description of the reporting plan for the data you will collect.
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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

16. Justification, Purpose and Use: For questions 16A through 16F, provide a brief justification for the survey, its purpose, goals,
and utility to managers. Specifically, describe how you will tabulate the data and what the statistical techniques you will use to
generalize the results to the entire customer population. Describe how you will use the data from the survey. Describe how you
will acknowledge any limitations related to the data, particularly in cases where we obtain a lower than anticipated response rate.
Note whether you intend the survey to measure a Government Performance and Results Act (GPRA) performance measure.
17. Federal Cost: Provide the cost estimate for the Federal government to administer the information collection, along with a
description of how you calculated the cost estimate (sample response provided). Contact your bureau/office ICCO for more
information or for assistance.
18. Survey Methodology Checklist: Carefully review each item and check each box to indicate your submission provides
the required description of each item.
19. Checklist for Submitting a Request to Use DOI Programmatic Clearance for Customer Satisfaction Surveys: Carefully
review each item and check each box to indicate your understanding and concurrence of each requirement.
20. Approval Package Content: Carefully review each item and check each box to indicate your package contains each of the
requirement elements listed.
NOTE: Your survey instrument document must show the OMB Control Number 1040-0001 and Expiration Date ##/##/###, and it
MUST include the following Statements somewhere on the instrument document (preferably at the bottom of page 1 or at the end
of the document):
Paperwork Reduction Act Statement: We are collecting this information subject to the Paperwork Reduction Act
(44 U.S.C. 3501) to [insert brief justification for collection of information]. Your response is voluntary and results we
will not share them publicly. We may not conduct or sponsor and you are not required to respond to a collection of
information unless it displays a currently valid OMB Control Number. OMB has reviewed and approved this survey
and assigned OMB Control Number 1040-0001, which expires ##/##/####.
Estimated Burden Statement: We estimate the [insert type of instrument] will take you ## minutes to complete,
including time to read instructions, gather information, and complete and submit your response. You may submit
comments on any aspect of this information collection to the Information Collection Clearance Officer, [Insert
Bureau/Office], [Insert mailing address].
21. Required Certifications: Completion of all information in this section is required before forwarding your approval
package to your bureau/office ICCO for review and processing.
Question 21A – Ensure the bureau/office statistician reviewing your information collection certifies the request satisfies
the requirements of the DOI Programmatic Clearance for Customer Satisfaction Surveys under OMB Control No. 10400001.
Question 21B – Ensure the requestor provides the requested contact information needed by the bureau/office and/or
Departmental ICCO to resolve questions or concerns.

Page 6 of 6