83C Justification for Change

Memorandum United States Department of Education

Institute of Education Sciences

National Center for Education Statistics

DATE: December 18, 2023

TO: Beverly Pratt, OMB

THROUGH: Carrie Clarady, OMB Liaison, IES

FROM: Tracy Hunt-White, NCES

SUBJECT: 2023–24 National Postsecondary Student Aid Study (NPSAS:24) Survey Item Response Categories and Student Website Change Request (OMB# 1850-0666 v.37)

The 2023-24 National Postsecondary Student Aid Study (NPSAS:24) is a nationally representative cross-sectional study of how students and their families finance education beyond high school in a given academic year. NPSAS is conducted by the National Center for Education Statistics (NCES) and was first implemented by NCES during the 1986–87 academic year and has been fielded every 3 to 4 years since. This request pertains to the 12th cycle in the NPSAS series being conducted during the 2023–24 academic year. NPSAS:24 will consist of a nationally representative sample of undergraduate and graduate students, and a nationally representative sample of bachelor’s degree completers. Subsets of questions in the NPSAS:24 student survey focus on describing aspects of the experience of bachelor’s completers in their last year of postsecondary education.

The request is to conduct all activities related to NPSAS:24, including materials and procedures related to: the NPSAS:24 student data collection, consisting of abstraction of student data from institutions and a student survey approved by OMB earlier in December 2023 (OMB#1859-0666 v. 36) and carried over respondent burden, procedures, and materials related to the NPSAS:24 institution sampling, enrollment list collection, and matching to administrative data files was approved by OMB in September 2023 (OMB#1859-0666 v. 35). The NPSAS:24 enrollment list collection from institutions takes place from October 2023 to October 2024, the student records and student survey data collections take place from February 2024 through November 2024.

This request is to modify survey response options for income questions and to edit the student website regarding texted reminders. This request does not introduce significant changes to the estimated respondent burden or the costs to the federal government.

Modifications to Student Survey Income Questions.

The NPSAS:24 student survey collects estimates of income in pre-set categories. The focus of the income questions and the response categories used differ depending on a student’s dependency status for financial aid purposes. If a student is determined to be dependent, then they are asked to estimate parents’ income using the response categories shown in the first column of table 1. If a student is determined to be independent, then the focus of the question is their own income, estimated using the response categories shown in the third column of table 1.

Once collected, NPSAS survey data will be combined with other administrative sources of data, most notably the income data provided in the Free Application for Federal Student Aid (FAFSA) data from the Central Processing System (CPS) for students who file a FAFSA, to derive public use income variables. In recent NPSAS administrations, the survey and derived income categories did not match. We would like to update the current survey categories to better align with the public facing derived variables. The proposed categories are shown in the second and fourth columns of table 1 for dependent and independent students respectively. Appendix A provides the updated facsimile of the student survey in both English (see pages K-72 and K-81) and Spanish (see pages K-266 and K-274) languages.

Table 1: Current and proposed income categories for N24HPARNC and N24HINCOM

Dependents (N24HPARNC) Current	Dependents (N24HPARNC) Proposed	Independents (N24HINCOM) Current	Independents (N24HINCOM) Proposed
Under $30,000 $30,000-$59,999 $60,000-$89,999 $90,000-$119,999 $120,000-$149,999 $150,000 or more Don’t know	Less than $10,000 $10,000-$29,999 $30,000-$49,999 $50,000-$74,999 $75,000-$99,999 $100,000-$124,999 $125,000-$149,999 $150,000 or more Don’t know	No income Less than $5,000 $5,000-$9,999 $10,000-$14,999 $15,000-$19,999 $20,000-$29,999 $30,000-$39,999 $40,000-$49,999 $50,000-$74,999 $75,000 or more Don’t know	No income Less than $5,000 $5,000-$9,999 $10,000-$19,999 $20,000-$29,999 $30,000-$49,999 $50,000-$74,999 $75,000 or more Don’t know

Revisions to the survey wording are highlighted below:

N24HINCOM

[If N24HMARR = 2]

Not including your spouse's income, what was your income for calendar year 2023 prior to taxes and deductions?

(Calendar year 2023 includes January 1, 2023 through December 31, 2023. Include all income you paid taxes on, including work, investment income, or alimony. Do not include any grants or loans you may have used to pay for school, or any money given to you by your family.)

[else]

What was your income for calendar year 2023, prior to taxes and deductions?

(Calendar year 2023 includes January 1, 2023 through December 31, 2023. Include all income you paid taxes on, including work, investment income, or alimony. Do not include any grants or loans you may have used to pay for school, or any money given to you by your family.)

1 = No income

2 = Less than $5,000

3 = $5,000 - $9,999

4 = $10,000 - $14,999 $19,999

5 = $15,000 - $19,999

6 5 = $20,000 - $29,999

7 6 = $30,000 - $39,999 $49,999

8 = $40,000 - $49,999

9 7 = $50,000 - $74,999

10 8 = $75,000 or more

-1 = Don't know

Help Text:
Estimate your gross income from the entire 2023 calendar year (January 1, 2023 – December 31, 2023). Do not include any income earned during 2024. Your gross income is the full amount before taxes, Social Security, and other deductions are taken out.

Include wages from off-campus jobs, on-campus jobs, work-study jobs, assistantships, fellowships, traineeships, summer jobs, or any other source. Also include income received from a trust fund.

Do not include scholarships, grants or loans, or any money given to you by your family.

If you are unsure, provide your best guess.

N24HPARNC

[If N24HPARST in (1, 5)]

What was your parents' (or guardians') combined income in calendar year 2023 (January 1, 2023 through December 31, 2023)?

[{If N24HPARST = 1} (If your parents are divorced and the parent you lived with more during the past 12 months is remarried, tell us about the combined income of that parent and the person he or she is married to.)]

[else if N24HPARST = 2]

What was your parent's (or guardian's) income in calendar year 2023 (January 1, 2023 through December 31, 2023)?

(Tell us about the parent or guardian with whom you lived most during the past 12 months. If you did not live with one parent more than the other, answer about the parent who provided more financial support during the last 12 months, or during the most recent year that you received support from a parent.)

[else if N24HPARST = 4]

What was your parent's (or guardian's) income in calendar year 2023 (January 1, 2023 through December 31, 2023)?

[else]

In calendar year 2023 (January 1, 2023 through December 31, 2023), what was the income of the parent (or guardian) with whom you lived most in the past 12 months?

(If you did not live with one parent more than the other, answer about the parent who provided more financial support during the last 12 months, or during the most recent year that you received support from a parent.)

1 = Under $30,000 Less than $10,000

2 = $10,000 - $29,999

2 3 = $30,000 - $59,999 $49,999

3 4 = $60,000 - $89,999 $50,000 - $74,999

5 = $75,000 - $99,999

4 6 = $90,000 - $119,999 $100,000 - $124,999

5 7 = $120,000 $125,000 - $149,999

6 8= $150,000 or more

-1 = Don't know

□ Parents (or guardians) are deceased

Help Text:

Estimate your parents' (or guardians') gross income from calendar year 2023 (January 1, 2023 – December 31, 2023) based on the ranges listed, even if your parents do not provide you with any financial assistance for your education. Gross income is the full amount before taxes, Social Security, and other deductions are taken out.

If you are unsure of the amount, provide your best guess.

After the 2024-25 financial aid year, income data in CPS on FAFSA filers will no longer be available for use in deriving these income variables which are critical to understanding financial aid eligibility in NPSAS. These data are considered Federal Tax Income (FTI) data. Consequently, NCES will be taking steps to assess the concordance of survey responses and administrative data as part of NPSAS:24. Since the current survey routing does not administer the item to all respondents (since data have been obtainable from the CPS for FAFSA filers), we will update the survey routing so that the income items will be administered to all dependent and independent individuals sampled regardless of FAFSA filing status.

Modifications to the Student Survey Website.

As part of the preparation process to send text messages to NPSAS:24 sample members, we are required to register the study and information about the communication campaign (i.e., reasons for sending messages) for review and adherence to the Telephone Consumer Protection Act (TCPA) and other policies surrounding Application-to-Person (A2P) messages. The Campaign Registry (TCR) is the hub that receives the study information, conducts a review, and provides a pass/fail response.

The initial review for NPSAS:24 failed for its lack of specificity in the language describing the study’s policy for sharing available text data. As a result, the text in red font was added to the English and Spanish versions of the Confidentiality page on the NPSAS student data collection website. Updates were made to pages J-14 (English) and J-157 (Spanish) of Appendix J.

Important note regarding text message communications for federal studies and the TCPA

The Telephone Consumer Protection Act (TCPA), under 47 U.S. Code §227, is a federal statute enacted in 1991 to safeguard consumer privacy. This legislation restricts telemarketing communications via voice calls, SMS texts, and fax without explicit prior consent. TCPA does not restrict NPSAS:24 research survey communications, provided those communications are made with the explicit consent of the participant or the contact is not made using an auto dialer.

During the course of data collection, you may receive text message reminders regarding survey participation. You have the option to opt out of text message reminders at any time. Neither text messaging contact nor consent information will be shared with any third parties unless required by law.

You can learn more about TCPA by clicking here https://www.fcc.gov/general/telemarketing-and-robocalls. If you have any questions regarding our use of text message reminders, you can reach us by e-mail at <<[email protected]>>//<<[email protected]>> or by phone at 877-677-2766.

"Neither text messaging contact nor consent information will be shared with any third parties unless required by law."

A revised application with the additional language has been submitted and we are awaiting the decision of the TCR.