# A. JUSTIFICATION

## 1. Purpose and Authority

In *Establishing a Research Agenda for Reauthorization of IDEA* (MSPD
Evaluation Support Center, 1995) the Office of Special Education
Programs (OSEP) laid out a plan for longitudinal research to inform the
reauthorization of the *Individuals with Disabilities Education Act*
(*IDEA*). The plan called for establishing several cohorts of children
and youth with disabilities that, if followed for a long enough period
of time, would create a picture of the experiences and achievements of
children and youth with disabilities, potentially from birth to young
adulthood.

In 1996, OSEP commissioned a longitudinal study of infants and toddlers
with disabilities who were receiving early intervention to answer key
questions about the children and families served under Part C of *IDEA*,
the services provided, and their achievements. In spring of 2000, OSEP
commissioned the Special Education Elementary Longitudinal Study (SEELS)
to provide information on the characteristics, experiences, and
achievements of 6- to 12-year-olds receiving special education as they
transition from elementary to middle and middle to high school. And at
the beginning of 2001, OSEP commissioned the second National
Longitudinal Transition Study (NLTS2), to provide data on youth as they
move through middle school and high school, to transition to the adult
world. The only glaring gap on this longitudinal spectrum were the early
childhood years---that is, children ages 3 through 5, no longer
toddlers, but not yet considered primary school age. This stage is
especially complex for children receiving special education services,
not just developmentally, but also in regard to the formal and informal
structure of the education and social service delivery systems.
Therefore, PEELS was commissioned to fill this gap. In 2005, authority
for PEELS was moved from OSEP to the new Institute for Education
Sciences' National Center for Special Education Research (NCSER). The
authorization for this collection of data is found in Public Law 105-17,
Section 674 (20 U.S.C. 1474) which permits the conduct of studies to
measure and evaluate the impact of the Individuals with Disabilities
Education Act (IDEA) and the effectiveness of States' efforts to provide
a free, appropriate public education to all children with disabilities.

## 2. Use of Information

The U.S. Department of Education (ED) has a variety of ongoing needs for
information about the implementation of special education for children
ages 3 through 5 with disabilities across the nation and the performance
of children receiving those services. These include:

-   Data that serve as indicators of *Government Performance and Results
    Act (GPRA)* objectives. In particular, PEELS addresses *IDEA*, Part
    B, Indicator 1.2, which states, "The percentage of preschool
    children receiving special education and related services who have
    readiness skills when they reach kindergarten will increase." The
    primary data source on children's early literacy and early numeric
    skills is the PEELS direct assessment. Direct assessments of
    (pre-)reading and (early) mathematics skills are conducted in each
    wave of PEELS. The final preschool assessment could be used to gauge
    academic readiness for kindergarten.

-   Information requested by Congress in regular reauthorizations of
    *IDEA*.

-   Information to respond to the many questions that are raised by
    policymakers, advocates, practitioners, parents, and researchers
    about children with disabilities, their families, and the programs
    that serve them.

Data collected from PEELS will supply much-needed information for all of
these purposes. Specifically, the following groups of individuals are
likely to benefit from the collection of the information:

-   Federal policymakers, who make decisions about special education and
    related services for young children with disabilities and the
    critical interfaces among these programs and other federally funded
    services and systems that affect children with disabilities and
    their families.

-   State early childhood special education policymakers (e.g., 619
    coordinators) who make decisions regarding state implementation of
    special education, state funding levels for special education, and
    other issues about programs and services for children with
    disabilities.

-   LEA and school administrators, who are responsible for implementing
    programs and services at the local level.

-   Practitioners and administrators in early childhood special
    education and related service systems, who will better understand
    the participation of young children with disabilities in those
    systems and the contribution of services to achievement.

-   Parents of children with disabilities who can use information on
    special education and related services and achievement to increase
    their own capacity to advocate effectively for their children.

-   Higher education faculty who conduct preservice training of special
    education teachers and related service personnel, who can use
    information on service and program characteristics that facilitate
    positive outcomes for children to improve the capabilities of future
    educators and practitioners.

-   Researchers who have access to this rich data source to conduct a
    variety of secondary analyses, develop comparable local or statewide
    follow-up studies, review the technical methods, or use the data for
    publication.

## 3. Method of Collection 

This is the final data collection for the PEELS study. Wave 5 includes a
child status report and a direct child assessment, which will allow an
examination of reading and math skills when children are in mid to late
elementary school. The child status report is sent to participating
districts to obtain information about the enrollment status of
participating children. Burden estimates are reported in Section 12.

## 4. Avoidance of Duplication

No national data previously existed on the characteristics, experiences,
or outcomes of children ages 3 through 5 receiving early childhood
special education services---data that are now available through PEELS.
The only other national data are state-reported counts of the number of
children served at a point in time each year, described by their age,
and the settings where the special education and related services are
received. None of the data collection instruments used previously in
PEELS or proposed for Wave 5 duplicate any existing national data that
describe preschool special education programs, the children receiving
services in these programs, or the children's performance on tests of
academic knowledge and skills. Although some states and local programs
may collect information on samples of their own schools or children,
state and local data are too diverse in content and quality to be
comparable and are an inappropriate base from which to extrapolate to
the nation as a whole.

## 5. Small Business Impact

No small businesses will be involved as respondents in this data
collection. Therefore, there will be no small business impacts.

## 6. Consequences of Not Collecting Information

In the absence of the data collection for PEELS, federal policy
regarding early childhood special education and related services will
continue to be made without a solid base of information on such
fundamental questions as the nature of the children served, the
instructional programs and services they receive, and the achievements
of children receiving early childhood special education and related
services. The final wave of data collection is particularly important
for 1) identifying predictors of literacy and math growth and 2)
describing how children who received preschool special education
services perform in elementary school.

The timing and frequency of data collection for PEELS is rooted in the
nature of both the PEELS population and the nature of the early
childhood programs they attend. Because preschool is not governed by
traditional American compulsory education, the early childhood programs
that the children in PEELS attend differ dramatically from each other
and from the more standard formal school system that characterizes
elementary and secondary schools. As a result, it was necessary to
conduct data collections immediately and repeatedly to capture these
vast differences and rapid changes. The schedule of data collection is
considered the minimum number and maximum spacing to obtain accurate
information on children's programs and outcomes.

## 7. Special Circumstances

The proposed data collection is consistent with 5DFR 1320.6 and
therefore involves no special circumstances.

## 8. Consultation Outside the Agency

Study design work was conducted by SRI International, and Westat was
contracted to conduct Waves 1-5 data collection, data cleaning,
analysis, and reporting. The design phase involved extensive input from
experts in the content areas and methods used by PEELS. First, a
stakeholder advisory panel was convened that included representatives of
many of the audiences that will be keenly interested in PEELS. The panel
helped develop the conceptual framework and define and prioritize the
research questions. The group met once in person for a day-long meeting
and engaged in a priority-setting exercise for the research questions
through an exchange of materials and a voting process.

Second, a technical work group (TWG) of researchers experienced in
child-based and longitudinal studies, early childhood education, and
special education advised on multiple aspects of the design, including
the child sampling approach and data collection procedures. TWG members
also received copies of all the data collection instruments. The TWG
held six phone conferences, and members reviewed all materials produced
in the design process. Each member supplied PEELS staff with written
comments and notes, and provided verbal feedback through telephone
conferences.

In addition, four nationally recognized experts in early childhood
special education served as consultants to the PEELS process. They
provided advice in all areas, with particular attention to the data
collection instruments and administration timeframe.

Finally, experienced researchers from SRI International and RTI guided
the development and completion of the PEELS design. Senior Westat staff
led the Waves 1-4 data collection, analysis, and reporting effort.
Members of the TWG, advisory panel, the four consultants, and senior
Westat staff are listed in exhibit 1.

+--------------------------+-------------------------------------------+
| **Exhibit 1. TWG,        |                                           |
| Stakeholder Panel,       |                                           |
| Consultants, and         |                                           |
| Contractor Staff         |                                           |
| Members**                |                                           |
+--------------------------+-------------------------------------------+
| **Name**                 | **Affiliation**                           |
+--------------------------+-------------------------------------------+
| ##                       |                                           |
| ### Technical Work Group |                                           |
+--------------------------+-------------------------------------------+
| Lizanne DeStefano        | University of Illinois, Urbana-Champaign  |
+--------------------------+-------------------------------------------+
| Marsha Brauen            | Westat                                    |
+--------------------------+-------------------------------------------+
| Elvira Hausken           | National Center for Education Statistics  |
+--------------------------+-------------------------------------------+
| Mary McEvoy              | CEED-University of Minnesota              |
+--------------------------+-------------------------------------------+
| Mabel Rice               | University of Kansas                      |
+--------------------------+-------------------------------------------+
| Carol Trivette           | Orelena Hawkes, Puckett Institute         |
+--------------------------+-------------------------------------------+
| Mark Wolery              | Frank Porter Graham Child Development     |
|                          | Center                                    |
+--------------------------+-------------------------------------------+
| **Consultants**          |                                           |
+--------------------------+-------------------------------------------+
| Donald Bailey            | University of North Carolina at Chapel    |
|                          | Hill                                      |
+--------------------------+-------------------------------------------+
| Michelle deFosset        | NECTAS                                    |
+--------------------------+-------------------------------------------+
| Robin McWilliam          | Formerly of the University of North       |
|                          | Carolina at Chapel Hill                   |
+--------------------------+-------------------------------------------+
| Rune Simeonsson          | University of North Carolina at Chapel    |
|                          | Hill                                      |
+--------------------------+-------------------------------------------+
| ##### Stakeholder Group  |                                           |
+--------------------------+-------------------------------------------+
| Catherine Burzio         | Parent Representative                     |
+--------------------------+-------------------------------------------+
| Jo Ann Edelin            | Alexandria City Public Schools, Office of |
|                          | Student Services                          |
+--------------------------+-------------------------------------------+
| Armineh Hacobian         | Parent Representative                     |
+--------------------------+-------------------------------------------+
| Debra Jervay-Pendergrass | Kennedy Institute-Stories Project         |
+--------------------------+-------------------------------------------+
| Luzanne Pierce           | National Association of State Directors   |
|                          | of Special Education                      |
+--------------------------+-------------------------------------------+
| Elizabeth Schaefer       | MA 619 Coordinator                        |
+--------------------------+-------------------------------------------+
| Lou McIntosh             | Merrywing Corporation                     |
+--------------------------+-------------------------------------------+
| Merle McPherson          | Maternal and Child Health Program         |
+--------------------------+-------------------------------------------+
| Jim O\'Brien             | Administration for Children, Youth and    |
|                          | Families                                  |
+--------------------------+-------------------------------------------+
| Mary Simmons             | Simpson County, RTC                       |
+--------------------------+-------------------------------------------+
| Gail Solit               | Gallaudet University Child Development    |
|                          | Center                                    |
+--------------------------+-------------------------------------------+
| Sharon Walsh             | Advisory Panel                            |
+--------------------------+-------------------------------------------+
| Pete Weilenmann          | Advisory Panel                            |
+--------------------------+-------------------------------------------+
| Terris Willis            | Advisory Panel                            |
+--------------------------+-------------------------------------------+
| Samara Goodman           | U.S. Department of Education, Office of   |
|                          | Special Education Programs                |
+--------------------------+-------------------------------------------+
| Nancy Treusch            | U.S. Department of Education/OSERS,       |
|                          | Office of Special Education               |
+--------------------------+-------------------------------------------+
| #####                    |                                           |
|  Design Contractor Staff |                                           |
+--------------------------+-------------------------------------------+
| SRI International and    |                                           |
| Research Triangle        |                                           |
| Institute                |                                           |
+--------------------------+-------------------------------------------+
| **Data Collection,       |                                           |
| Analysis and Reporting   |                                           |
| Staff at Westat**        |                                           |
+--------------------------+-------------------------------------------+
| Elaine Carlson, Project  |                                           |
| Director                 |                                           |
+--------------------------+-------------------------------------------+
| Bill Frey and Ann        |                                           |
| Webber, Assessment       |                                           |
| Directors                |                                           |
+--------------------------+-------------------------------------------+
| Ron Hirschhorn and Ed    |                                           |
| Dolbow, Senior Systems   |                                           |
| Designers                |                                           |
+--------------------------+-------------------------------------------+
| Linda LeBlanc, Data      |                                           |
| Collection Manager       |                                           |
+--------------------------+-------------------------------------------+
| Hyunshik Lee, Senior     |                                           |
| Statistician             |                                           |
+--------------------------+-------------------------------------------+

The 60 day Federal Register notice was published on Tuesday, June 10,
2008 in Volume 73, number 112, p. 32684. No public comments were
received during this time period.

**9. Reimbursement of Respondents**

## Research suggests that the use of participant incentives improves response rates, reduces bias, and reduces costs. Incentives enhance the quality of the data by ensuring that nonresponse is kept to a minimum. Recruiting reluctant participants and converting refusals are time-consuming and expensive endeavors, and can introduce bias into survey results. 

In previous waves, PEELS provided incentives. The following incentives
for the Wave 5 direct child assessment are proposed, which are
consistent with those used in earlier waves: a \$1 toy for children at
the time of testing and a \$15 gift card for families that transport
their children for testing or allow testing to be done in their home.
The toy and gift card are both given at the time of assessment. The
child status report does not include any respondent incentives.

## 10. Assurances of Confidentiality

In Waves 1-4, ED executed a plan for ensuring that all data collected as
part of this study remained confidential. ED intends to follow this plan
in Wave 5 of the study. Respondents were assured that confidentiality
was maintained, except as required by law. Specific steps to guarantee
confidentiality included the following:

-   Identifying information about the families and respondents (e.g.,
    respondent name, address, and telephone number) was not entered into
    the analysis data file, but was kept separate from other data and
    was password protected. A unique identification number for each
    participating child and school district was used for building raw
    data and analysis files.

-   In emails, participating children were referred to by first name,
    last initial, and unique identification number. School districts
    were referred to by PEELS identification number. Files containing
    more information were password protected.

-   A fax machine used to send or receive documents containing
    confidential information was kept in a locked field room, only
    accessible to study team members. When sending faxes, study staff
    called ahead to make sure the authorized recipient was waiting for
    the fax.

-   Confidential materials were printed on a printer located in a
    limited access field room. When printing documents containing
    confidential information from shared network printers, authorized
    study staff were present and retrieved the documents as soon as
    printing was complete.

-   In public reports, findings are presented in aggregate by type of
    respondent (e.g., parents' perceptions of service delivery) or for
    subgroups of interest (e.g., social functioning of children who
    begin receiving early childhood special education at age 3, compared
    to age 5). No reports identify individual respondents, local
    programs, or schools.

-   Access to the child sample files is limited to authorized study
    staff only; no others are authorized such access.

-   All members of the study team were briefed regarding confidentiality
    of the data. Each person involved in the study signed and had
    notarized an affidavit of nondisclosure attesting to his/her
    understanding of the significance of the confidentiality requirement
    (exhibit 2).

-   A control system was in place, beginning at sample selection, to
    monitor the status and whereabouts of all data collection
    instruments during transfer, processing, coding, and data entry.
    This included sign in/sign out sheets and the hand-carrying of
    documents by authorized project staff only.

-   All data were stored in secure areas accessible only to authorized
    staff members. Computer-generated output containing identifiable
    information was maintained under the same conditions.

-   When any hard copies containing confidential information were no
    longer needed, they were shredded.

-   Micro-level data were released through restricted-use data sets and
    only after the data had been perturbed in accordance with Disclosure
    Review Board (DRB) instructions.

Exhibit 2. Affidavit of Nondisclosure

(Job Title) (Date of Assignment to PEELS Project)

**Westat PEELS**

> (Organizations, State or local (Data Base or File Containing

agency or instrumentality) Individually Identifiable Information)

**1650 Research Blvd.**

**Rockville, MD 20850**

(Address)

I, , do solemnly swear (or affirm) that when given access to the subject
data base or file, I will not

(i) use or reveal any individually identifiable information furnished,
    acquired retrieved or assembled by me or others, under the
    provisions of Section 406 of the General Education Provisions Act
    (20 U.S.C. 1221e-1) for any purpose other than statistical purposes
    specified in the PEELS surveys, project or contract;

(ii) make any disclosure or publication whereby a sample unit or survey
     respondent could be identified or the data furnished by or related
     to any particular person under this section can be identified; or

(iii) permit anyone other than the individuals authorized by the
      Department of Education to examine the individual reports.

> (Signature)

(The penalty for unlawful disclosure is a fine of not more than
\$250,000 (under 18 U.S.C. 3559 and 3571) or imprisonment for not more
than 5 years, or both. The word "swear" should be stricken out wherever
it appears when a person elects to affirm the affidavit rather than to
swear to it.)

State of:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

County of;\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Sworn and subscribed to me before a Notary Public in and for the
aforementioned County and State this \_\_\_\_\_\_\_\_ day of
\_\_\_\_\_\_\_\_\_\_\_2003.

> (Notary Public)

My Commission Expires:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

## 11. Sensitive Items

No questions of a sensitive nature are included in the direct child
assessment.

## 12. Estimates of Burden

Estimates of respondent burden for the Child Status Report is estimated
to be 6,690 minutes or 108 hours for Wave 5. It is estimated that
approximately 215 site coordinators will fill out the Child Status
Report and it will take approximately 30 minutes to complete. These
estimates are based on several factors:

-   the length of the instrument,

-   number of target respondents, and

-   average time for completion in prior waves.

## 

Respondent costs result from the investment of time in completing
questionnaires, (e.g., school staff completing mail questionnaires,
families responding to telephone interviews). Estimates of response time
for each data collection instrument are presented in response to item \#
12 above. No dollar costs have been associated with the time estimates
because salaries of school personnel vary widely.

13\. **Estimated Annual Cost Burden to Respondents**

There are no start-up costs for respondents.

## 14. Estimated Annual Cost Burden to Federal Government

The total cost for Waves 2-4 was \$11,445,447. This included costs for
all aspects of data collection, data cleaning, coding, and processing;
descriptive, explanatory, and longitudinal analyses; preparation of
various project reports; and general project management and coordination
with the government project officer. NCSER estimates that costs for Wave
5 will be roughly \$2,803,000.

## 15. Program Changes in Burden/Cost Estimates

There is a program change of 108 burden hours. This is due to the fact
that the previous collection was discontinued and is now being
reinstated with changes for wave 5.

## 16. Plans/Schedules for Tabulation and Publication

Westat will generate descriptive statistics that summarize and describe
the data from the Wave 5 assessment. Descriptive statistics (means and
standard errors) will be used to describe the data in a series of data
tables. This aspect of the analysis will closely mirror analyses
conducted in Waves 1-4 to help identify changes over time.

Each of the Waves 1-5 data tables will be accompanied by a corresponding
table with standard error estimates. All the data in the descriptive
tables will be weighted to represent cross-sectional national estimates
for each of Waves 1, 2, 3, 4, and 5. Westat will test for the
significance of changes over time (between the first and last relevant
wave of data collection) within subgroups defined by age cohort,
race/ethnicity, etc.

As more data become available, our analysis tasks have increasingly
focused on model-building activities, such as achievement growth, and we
expect that will continue to be the case in Wave 5. Figure 1 provides a
general model that guides the PEELS analyses.

![](media/image1.png){width="6.247916666666667in"
height="3.251388888888889in"}

As analysts generate and report descriptive statistics for PEELS, we
will make every effort to contextualize those statistics by reporting
results of similar analyses from extant data sources. This will help
analysts and readers alike to interpret results. A number of ongoing
studies share overlapping populations and/or assessment instruments with
PEELS, including the Early Childhood Longitudinal Study, Kindergarten
Cohort (ECLS-K); Head Start Impact Study; Head Start National Reporting
System; Classroom Literacy Interventions and Outcomes; National Early
Intervention Longitudinal Study; and Special Education Elementary
Longitudinal Study.

**Reporting Mechanisms**

A variety of mechanisms are being used to make the PEELS data available
to the public. In 2006, Westat created a restricted-use data set that
contained final Wave 1 and Wave 2 data. Wave 3 was added in 2007, and
Wave 4 will be released in 2008. A similar data set will be created
following Wave 5. In addition, in 2008, NCSER released a web-based table
production system for PEELS. Westat will update the data analysis system
(DAS) with data as they become available. The DAS will allow the public
to access most of the PEELS data while denying access to micro-level
data.

A number of PEELS reports will be prepared under contract with Westat.
These include a wave overview report and thematic reports suitable for
publication in referred journals. The PEELS reporting agenda also
includes some short reports, including 2 two-pagers and an annual
newsletter (see exhibit 4).

**Exhibit 4. Schedule of Wave 5 reporting activities**

  ----------------------------------------- -----------------------------
  Task                                      Estimated completion date

  Draft Wave 5 methods report               9/15/09

  Final Wave 5 methods report               11/1/09

  Rough draft of assessment data            12/15/09

  Final report of assessment data           1/15/10

  Draft thematic reports (2)                1/20/10

  Final thematic reports (2)                3/20/10

  Draft Overview Report                     3/15/10

  Final Overview Report                     5/15/10
  ----------------------------------------- -----------------------------

**17. Expiration Date Omission Approval**

Not applicable.

**18. Exceptions**

No exceptions are taken.