OMB memo

U.S. DEPARTMENT OF EDUCATION INSTITUTE OF EDUCATION SCIENCES NATIONAL CENTER FOR EDUCATION STATISTICS

TO:	Rochelle W. Martinez	August 17, 2009
THROUGH:	Kathy Axt Katrina Ingalls
FROM:	Kashka Kubzdela
SUBJECT:	Request for Clearance for the Proposed Postsecondary Education Quick Information System (PEQIS) Survey on Students with Disabilities at Postsecondary Education Institutions.

Justification

The National Center for Education Statistics (NCES), U.S. Department of Education (ED) proposes to use the Postsecondary Education Quick Information System (PEQIS) to conduct a survey on students with disabilities at postsecondary education institutions. This PEQIS survey, under OMB clearance #1850-0733, is being conducted to provide the Office of Special Education and Rehabilitative Services (OSERS), U.S. Department of Education, with current information about students with disabilities at postsecondary institutions, and the services and accommodations that the institutions provide to these students.

Increased enrollment of persons with disabilities in postsecondary institutions, along with key legislation such as the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973 (Section 504), have prompted numerous questions regarding access, support, and accommodations for students with disabilities in postsecondary education institutions. Postsecondary institutions are required by law to provide reasonable accommodations to students with disabilities to ensure equal access to educational opportunities to these students. However, the most recent nationally representative data available from postsecondary institutions about the enrollment of students with disabilities and the support services and accommodations these institutions provide to students with disabilities was collected in a PEQIS survey conducted in 1998. The previous PEQIS survey found that 72 percent of 2-year and 4-year postsecondary institutions enrolled students with disabilities, with an estimated 428,000 students with disabilities enrolled at these institutions in 1996-97 or 1997-98. The number of students with disabilities represents only those students who had identified themselves in some way to the institution as having a disability, since these are the only students about whom the institutions could report. This is because postsecondary institutions are not required to report information about students with disabilities, unlike at the elementary-secondary level where reporting is required under the Individuals with Disabilities Education Act (IDEA). The proposed PEQIS survey will provide nationally representative data from postsecondary education institutions about students with disabilities in 2008-09.

The PEQIS survey, under OMB clearance #1850-0733, is authorized under Section 153 (a) of the Education Science Reform Act of 2002 (Public Law 107-279), which states that the purpose of NCES is “to collect, report, analyze, and disseminate statistical data related to education in the United States and in other nations.”

Overview of data collection

Westat will collect the information for the Early Childhood, International, and Cross-Cutting Studies Division, NCES, U.S. Department of Education, using PEQIS. Westat is responsible for the questionnaire development; sample design; data collection; telephone followup; editing, coding, keying, and verification of the data; and production of tabulations and the report detailing the results of the survey.

Substantial development work was conducted for this survey. Much of this work focused on refining the disability categories to align them with the categories that postsecondary institutions use; these categories are discussed in more detail in the section below describing the data collection instrument. Additional development work focused on developing new questions on accessibility, services and accommodations provided to the general public, and the emerging area of Universal Design. Development work included literature review, several rounds of feasibility calls (where respondents provide comments about survey topics or questions, but do not complete the survey), and two pretests. Each round of feasibility calls and each pretest included fewer than 10 respondents. In addition, the survey used for each iteration was very different. These rounds of design and testing were aimed at refining the survey instrument.

The data collection will be accomplished by means of a self-administered survey of approximately 1,600 4-year and 2-year Title IV degree-granting postsecondary institutions in the 50 states and the District of Columbia. Respondents will have the option of completing the survey with a traditional paper and pencil questionnaire or with a Web version of the questionnaire. The paper version of the questionnaire is limited to three pages of questions. The information needed to complete the survey will be readily available to respondents, and the survey can be completed by most institutions in 30 minutes or less. These procedures are typical of PEQIS and FRSS surveys, and result in minimal burden on respondents.

Questionnaires and cover letters will be mailed to the PEQIS coordinator of institutions in the PEQIS panel (see description of the PEQIS panel under respondent universe). The cover letter will include a detailed description of the most appropriate respondent(s).

Telephone followup for nonresponse will begin about 3 weeks after the questionnaires have been mailed to the institutions. Experienced telephone interviewers will be trained to conduct the nonresponse followup and will be monitored by Westat supervisory personnel during all interviewing hours. The response rates for all PEQIS surveys have been greater than 90 percent.

Data collection instruments

A cover letter (Attachment 1) and questionnaire (Attachment 2) will be mailed to each institution in September or early October 2009. The cover letter requests the participation of the institution and introduces the purpose and content of the survey. It also notes that the survey should be completed by the person or persons most knowledgeable about students with disabilities, and the services provided to these student by the institution. The cover letter also includes instructions on how to complete and return the survey, as well as contact information in case of queries. Included in the mailing will be information about the option to complete a Web version of the survey.

The questionnaire first asks whether institutions had any students enrolled who identified themselves as having a disability during the 2008-09 12-month academic year. Institutions that had self-identified students with disabilities are asked to respond to a set of questions about enrollment of students with disabilities (questions 2 through 6) and support services and accommodations designed for students with disabilities (question 7). The questions on enrollment ask institutions to indicate the total number of students with disabilities enrolled at the institution and the number of students in each of several specific disability categories. Institutions are asked to indicate whether they provided unduplicated or duplicated counts. In unduplicated counts, each student with a disability is counted only once regardless of the number of disabilities he or she has. In duplicated counts, students with multiple disabilities are counted multiple times. Institutions are also asked whether the counts include students who identified themselves as having a disability to the institution, received services and accommodations, and/or whose disabilities were verified.

All institutions are asked to respond to the remainder of the questionnaire on institutional policies, materials, and activities. Question 8 asks institutions about types of documentation institutions accept as verification of a disability while question 9 asks about the extent to which institutions work with a state vocational rehabilitation agency. Questions 10 through 14 ask institutions about institutional materials and activities designed to assist students with disabilities. These include materials designed to encourage students with disabilities to identify themselves to institutions, materials and activities designed to assist faculty and staff in working with these students, the extent to which institutions’ main websites follow accessibility guidelines for users with disabilities, whether institutions conduct various activities related to accessibility, and whether institutions provide various services and accommodations to the general public. Finally, institutions are asked to identify barriers to Universal Design, an approach that integrates accessibility features into the overall design of products and environments.

Review by persons outside the agency

All development work was conducted in close collaboration with OSERS. Input was also received from staff at the Institute of Education Sciences, National Center for Special Education Research, ED. The various draft versions of the instrument were also reviewed and tested with individuals in the field knowledgeable about students with disabilities at postsecondary institutions. In addition to multiple rounds of feasibility calls, the questionnaire was pretested with knowledgeable respondents at postsecondary institutions, typically the director of the office that provided disability support services to students. Based on input from these respondents and OSERS, the questionnaire was revised for this submission (see Attachment 2).

Survey cost

The survey is estimated to cost the Federal government about $490,000, including about $450,000 for contractual costs and $40,000 in costs to the Federal government for salaries and expenses. Based upon costs of past PEQIS surveys, contractual costs are divided into the subtask costs shown in Exhibit 1.

Exhibit 1. Estimated contractual costs by subtask

Subtask	Cost
Survey preparation	85,000
Data collection	225,000
Data analysis	50,000
Report preparation and dissemination	90,000
Total	450,000

Time schedule

The questionnaires are scheduled to be mailed in September or early October 2009. About 3 weeks after mailout, Westat will begin telephone followup for nonresponse. Data collection is scheduled for completion about 18 weeks after mailing. See Exhibit 2 for the anticipated time schedule.

Exhibit 2. Anticipated data collection schedule

	Cumulative workdays
	From submission to RIMS/OMB	From OMB approval
Package to RIMS/OMB	0	-
Package approved by OMB	45	0
Mail-out of questionnaire	55	10
Follow up started	70	25
Follow up completed	145	100

Plan for tabulation and publication

Most of the analyses of the questionnaire data will be descriptive in nature, providing OSERS, NCES, and other data users with tables and appropriate explanatory text. Reports of the findings will be distributed to the data requester, survey respondents, and upon request to other interested individuals and organizations, as well as published on the NCES website. Survey responses will be weighted to produce national estimates. Tabulations will be produced for each data items. Crosstabulations of data items will be made with the following classification variables:

• Type of institution (2-year public, 2-year private, 4-year public, 4-year private)

• Size of institution (less than 3,000; 3,000-9,999; 10,000 or more)

Reviewing statisticians

Statistician Adam Chu of Westat (301-251-4326) was consulted about the statistical aspects of the design.

Respondent universe

This survey will be sent to the approximately 1,600 postsecondary institutions in the PEQIS panel. The sampling frame for the current PEQIS panel was constructed from the 2005-06 Integrated Postsecondary Education Data System (IPEDS) “Institutional Characteristics” file. Institutions eligible for the PEQIS frame included 2-year and 4-year (including graduate-level) Title IV-eligible degree-granting institutions located in the 50 states and the District of Columbia. In 2006, the frame included a total of 4,265 institutions.

The PEQIS sampling frame was stratified by instructional level (4-year, 2-year), control (public, private not-for-profit, private for-profit), highest level of offering (doctor’s/first-professional, master’s, bachelor’s, less than bachelor’s), and total enrollment. Within each of the strata, institutions were sorted by region (Northeast, Southeast, Central, West), and by whether the institution had a relatively high minority enrollment. The sample of institutions was allocated to the strata in proportion to the aggregate square root of total enrollment. Institutions within a stratum were sampled with equal probabilities of selection. In 2006, the sample included a total of 1,627 institutions.

Each institution in the PEQIS panel was asked to identify a campus representative to serve as survey coordinator. The campus representative facilitates data collection by identifying the appropriate respondent for each survey and forwarding the questionnaire to that person.

Statistical methodology

Nonresponse weight adjustments will be used to correct for unit nonresponse. Variances will be estimated using the jackknife replication method. Estimates produced during the PEQIS panel design stage, based on characteristics of the institutions, yielded coefficients of variation (cv’s) in the range of 2 to 4 percent for most national estimates, with estimates for subgroups somewhat higher. Similar cv’s are expected for this survey.

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