MLRevised Supporting Statement Part A_2013[1]

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Institute of Education Sciences (IES) has three education training grant programs that provide funds to universities to support three types of training programs in the education sciences: 1) Predoctoral Interdisciplinary Research Training Programs, 2) Postdoctoral Research Training Program, and 3) Postdoctoral Research Training Program in Special Education. To determine the quality and effectiveness of these grants, IES staff survey program participants annually as to their satisfaction with their program and their accomplishments. The populations of pre- and postdoctoral fellows are small enough to make a census survey manageable and to make a sample not reliable for subgroup findings.

Participants currently in the program will be surveyed every year until they complete. Participants who have completed their programs will be surveyed for 5 years following the completion of their training (predoctoral fellows will be tracked for 5 years following the completion of their fellowship and doctorate program). The purpose of surveying completed fellows is to determine whether participants in the pre- and postdoctoral fellows program continue to work in and contribute to the field of education research. Therefore, data on their annual status and contributions to the field of education research will be collected. However, to decrease burden on fellows over time, we will not survey them beyond 5 years.

The National Center for Education Research (NCER) of the Institute of Education Sciences (IES), U.S. Department of Education, is conducting this study, as authorized under Public Law 107-279, Title I, Part C, Section 131(a) and 131(b) of the Education Sciences Reform Act of 2002 and U.S. Code Title 20 Section 9543 which states:

(a) ESTABLISHMENT.—There is established in the Institute a National Center for Education Research (in this part referred to as the ‘‘Research Center’’).

(b) MISSION.—The mission of the Research Center is—

(1) to sponsor sustained research that will lead to the accumulation of knowledge and understanding of education, to—

1. ensure that all children have access to a high quality education;

2. improve student academic achievement, including through the use of educational technology;

3. close the achievement gap between high-performing and low-performing students through the improvement of teaching and learning of reading, writing, mathematics, science, and other academic subjects; and

4. improve access to, and opportunity for, postsecondary education;

(2) to support the synthesis and, as appropriate, the integration of education research;

(3) to promote quality and integrity through the use of accepted practices of scientific inquiry to obtain knowledge and understanding of the validity of education theories, practices, or conditions; and

(4) to promote scientifically valid research findings that can provide the basis for improving academic instruction and lifelong learning.

Furthermore, the Director is to ensure that the activities conducted through IES are meeting the needs of the larger community. In particular, Public Law 107-279, Title I, Part C, Section 185 of the Education Sciences Reform Act of 2002 and U.S. Code Title 20 Section 9543 states that IES must address performance management:

SEC. 185. PERFORMANCE MANAGEMENT.

The Director shall ensure that all activities conducted or supported by the Institute or a National Education Center make customer service a priority. The Director shall ensure a high level of customer satisfaction through the following methods:

(1) Establishing and improving feedback mechanisms in order to anticipate customer needs.

(2) Disseminating information in a timely fashion and in formats that are easily accessible and usable by researchers, practitioners, and the general public.

(3) Utilizing the most modern technology and other methods available, including arrangements to use data collected electronically by States and local educational agencies, to ensure the efficient collection and timely distribution of information, including data and reports.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The survey information is used by IES staff to write an annual report that examines how the grants and their supported programs have contributed to the development of new education researchers. IES staff use this information to improve the training programs and to provide general feedback to programs about major themes arising from the analysis.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The survey will be conducted online so that (1) participants can easily access the survey, (2) all responses can be submitted electronically, and (3) participants can save and return to their responses. These features will also decrease the amount of IES staff effort by eliminating the need for keying data and minimizing respondent errors. We are currently working on making previous year’s submissions available to the fellows so that they have prepopulated forms that need only to be updated, thereby further decreasing their effort.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use of the purposes described in Item 2 above.

The survey collects data from individuals taking part in the education programs that is not available from other sources. The information gathered provides important details regarding fellows’ satisfaction with the training programs and post-fellowship status.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The survey does not impact small businesses or other small entities.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The survey is in compliance with 5 CFR1320.5. Without the survey, IES will not be in a position to determine whether its education training grants programs were achieving their purpose and will not be able to make adjustments to improve the results of these grant programs. The annual nature of the survey is in sync with the annual nature of the training provided by the universities.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

There are no special circumstances that would cause information collection to be conducted in any of the manners listed above.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

The public has had the opportunity to comment during both the 60-day and 30-day comment period notices. Also, we have received feedback from previous respondents asking if the survey could be conducted online and if they could receive prepopulated surveys. We have implemented the first recommendation and are piloting the feasibility of the second. We expect that both recommendations for improvement will be fully realized by the time of the next survey.

8. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts will be provided to respondents.

8. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

From a privacy standpoint, the survey cover letter cites the Privacy Act to assure respondents that the appropriate safeguards are implemented to avoid unauthorized use or disclosure of individually identifying information. The statements below will appear: The data collection activities will be conducted in compliance with the Privacy Act of 1974.

The data have been and will continue to be stored electronically. It is retrievable by name, and the data are kept after the report is complete. The electronic files are kept in a password protected server. The security protections for the content have been identified in the SORN and PIA documents. The PIA and SORN are added assurances of confidentiality that IES is establishing protections to reasonably safeguard the respondents’ information from improper disclosure, whether intentional or unintentional.

The assurance of confidentiality for the survey of participants is as follows:

Information collected for this study come under the confidentiality and data protection requirements of the Institute of Education Sciences (The Education Sciences Reform Act of 2002, Title I, Part E, Section 183). Information that could identify an individual or institution will be separated from the survey responses submitted, kept in secured locations, and be destroyed as soon as they are no longer required. Survey responses will be used only for research purposes. The reports prepared for the study will summarize findings across individuals and institutions and will not associate responses with a specific district, school, or person. The data collection activities will be conducted in compliance with the Privacy Act of 1974.

The above statement describes the intent to keep information collected on fellows’ opinions on the quality of the fellowship programs confidential. Such information might be considered prejudicial by those running the programs or other participants if it was critical of the program. For this reason, this information will be kept confidential and reported only in aggregated data.

8. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

No questions of this type are included in the survey.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.

Table 1: Respondents’ Burden from Annual IES Fellows Survey (Predoctoral Fellows)

Year	Estimated # of Pre-Docs	Cost per hour*	Time to Complete Survey (hours)	Cost per respondent	Total time to complete survey (hours)	Total Respondent Burden ($)
1	500	$ 19.40	0.35	$ 6.79	175	$ 3,395.00
2	520	$ 19.40	0.35	$ 6.79	182	$ 3,531.00
3	540	$ 19.40	0.35	$ 6.79	189	$ 3,667.00

Table 2: Respondents’ Burden from Annual IES Fellows Survey (Postdoctoral Fellows)

Year	Estimated # of Postdocs	Cost per hour**	Time to Complete Survey (hours)	Cost per respondent	Total time to complete survey (hours)	Total Respondent Burden ($)
1	100	$ 28.74	0.35	$ 10.06	35	$1,006
2	105	$ 28.74	0.35	$ 10.06	36.75	$1,056
3	110	$ 28.74	0.35	$ 10.06	38.5	$1,106

The average annual respondents and responses will be 625 and the average annual burden hours will be 218.75 burden hours per year.

*Predocs receive a fellowship in the amount of $40,500 per 12 month year that covers stipend, tuition support, and fringe benefits. Using 2,088 working hours per year, this works out to a fellowship of $19.40 per hour.

**Postdocs receive a fellowship in the amount of $60,500 per 12 month year that covers stipend and fringe benefits. Using 2,088 working hours per year, this works out to a fellowship of $28.74 per hour.

9. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)

There are no capital costs, no start-up costs, and no costs for operation and maintenance and purchase of services.

8. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

The survey, data analysis, and report writing will be handled by IES education research analysts. Because the survey is conducted online, the analysis is done in house, and the report will be published electronically, there are no equipment, printing, and overhead costs. The annual cost to the Federal government is determined by the time spent by the education research analysts which is described in the table below.

Annual Time and Its Cost Required by IES Education Research Analysts

Task	Predoctoral Survey	Postdoctoral Survey	Special Education Postdoctoral Survey	Total
Data collection and quality control	60 hours	60 hours	60 hours	180
Data compilation and tabulation	120 hours	60 hours	20 hours	200
Report writing	120 hours	60 hours	60 hours	240
Total Hours	300	180	140	620
Education Research Analyst’s salary & benefits per hour	$71.60	$71.60	$71.60	$71.60
Annual Cost	$21,480	$12,888	$10,024	$44,392

8. Explain the reasons for any program changes or adjustments.

The number of individuals trained by the IES programs has increased over time. This survey will be sent to all current fellows and former fellows who have completed their training within the past 5 years. Thus, the total number respondents has grown since the survey was established. The number of questions has also increased slightly, so there is a modest increase in the amount of time each respondent may spend filling in the survey relative to past years. To help reduce the burden, we have taken the following three steps: (1) the survey will be administered online, (2) respondents will receive targeted questions based on where they are in their programs (e.g., if they have not completed their programs or if they finished years ago, they will receive only the most relevant questions), and (3) fellows will be tracked for only 5 years after completing their fellowships. These last three elements all reduce the burden. Given these adjustments, the overall burden for a respondent is approximately 20 minutes.

8. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

• Links to the survey will be sent out by email in December or January, (pending OMB approval).

• Survey responses will be due by February.

• Follow-up data collection for non-respondents will continue to the end of March.

• Data analysis will take place from March through June. This analysis will make use of tabulations. No complex analytical techniques will be used.

• The report will be written in August.

• The report will be published in November.

8. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Approval is not being sought to not display the expiration date for OMB approval of the information collection.

8. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

No exceptions are being sought for this work.

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