November 21, 2014

High School Longitudinal Study of 

2009 (HSLS:09) Second Follow-up

Field Test and Main Study Panel 

Maintenance 2015

Supporting Statement

Part A

Request for OMB Review

OMB# 1850-0852 v.15

National Center for Education Statistics

U.S. Department of Education

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TABLE OF CONTENTS

Section Page

A. Justification......................................................................................................................... 1

A.1 Circumstances Necessitating Collection of Information.......................................... 1

A.1.a Purpose of This Submission......................................................................1

A.1.b Legislative Authorization..........................................................................3

A.1.c Prior and Related Studies..........................................................................3

A.2 Purpose and Use of Information Collection............................................................. 4

A.2.a Content Justifications................................................................................7

A.3 Use of Improved Information Technology............................................................. 13

A.3.a Postsecondary Transcripts: HSLS:09 PETS ................................................14

A.3.b. Financial Aid Records Collection: HSLS:09 FAR .....................................14

A.4 Efforts to Identify Duplication and Use of Similar Information ............................ 15

A.5 Impact on Small Businesses or Other Small Entities............................................. 16

A.6 Consequences of Collecting the Information Less Frequently .............................. 17

A.7 Special Circumstances Relating to Guidelines of 5 CFR 1320.5........................... 18

A.8 Consultations Outside NCES ................................................................................. 18

A.9 Provision of Payment or Gift to Respondents........................................................ 18

A.10 Assurance of Confidentiality Provided to Respondents......................................... 19

A.11 Justification for Sensitive Questions...................................................................... 23

A.12 Estimates of Annualized Burden Hours and Their Cost to Respondents............... 23

A.13 Estimates of Total Annual Cost Burden to Respondents....................................... 24

A.14 Annualized Cost to the Federal Government ......................................................... 25

A.15 Reasons for Program Changes ............................................................................... 25

A.16 Publication Plans and Project Schedule ................................................................. 26

A.17 Reason(s) Display of OMB Expiration Date Is Inappropriate ............................... 27

A.18 Exceptions to Certification for Paperwork Reduction Act Statement.................... 27

EXHIBITS

Number Page

Exhibit A-1. HSLS:09 Data Collection Components, by wave of data collection ........................2

Exhibit A-2. Longitudinal design for the HSLS:09 ninth-grade cohort: 2009–25.......................17

Exhibit A-3. Estimated Burden for HSLS:09 Second Follow-up..................................................24

Exhibit A-4a. Total Costs to NCES ...............................................................................................25

Exhibit A-4b.Total Contract Costs................................................................................................25

Exhibit A-5. Operational Schedule for HSLS:09 Second Follow-up Field Test .........................26
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ATTACHMENTS

Appendix A HSLS:09 Technical Review Panel (TRP) Contact Information

Appendix B Confidentiality for Administrative Record Matching

Appendix C Data Security Language for Vendor Contracts

Appendix D Respondent Communication Materials

Appendix E Facsimiles for the HSLS:09 Second Follow-up Interview, Reinterview, and 

Abbreviated Interview

Appendix F Transcript Data Request Contacting Materials and Data Elements

Appendix G Student Records Request Contacting Materials and Data Elements
Supporting Statement Request for OMB Review (SF83I) A. Justification

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A. JUSTIFICATION

A.1 Circumstances Necessitating Collection of Information

A.1.a Purpose of This Submission

The High School Longitudinal Study of 2009 (HSLS:09) is conducted by the National Center for 

Education Statistics (NCES), part of the Institute of Education Sciences within the U.S. Department of 

Education. The primary contractor for this study is the Research Triangle Institute (RTI) International, 

and subcontractors include Coffey Consulting; Hermes; HR Directions; Research Support Services; and 

Strategic Communications, Inc, with Dr. Sandy Baum as a consultant.

This request is to conduct the HSLS:09 Second Follow-up field test in 2015 and panel 

maintenance for the main study sample, and to describe the planned data collections for the main study. 

Following the field test study, NCES will provide the Office of Management and Budget (OMB) with a 

memorandum summarizing any changes planned for the main study data collection, and a revised OMB 

package. The main study will include a survey of panel members, collection of their postsecondary

transcripts and financial aid records, and file matching to various extant data sources. The materials that 

will be used in the 2015-16 main study will be based upon the field test materials included in this 

submission. Additionally, this submission is designed to adequately justify the need for and overall 

practical utility of the full study and to present the overarching plan for all of the phases of the data 

collection, providing as much detail about the measures to be used as is available at the time of this 

submission. As part of this submission, NCES is publishing a notice in the Federal Register allowing first 

a 60- and then a 30-day public comment period. For the final proposal for the full study, after the field 

test, NCES will publish a notice in the Federal Register allowing an additional 30-day public comment 

period on the final details of the 2015-16 main study. This submission includes:

 A membership list of the Technical Review Panel (TRP) for the data collection component of 

HSLS:09 (appendix A);

 Confidentiality procedures for administrative record matching (appendix B);

 The data security language for vendor contracts (appendix C)

 Communication materials for survey respondents (appendix D);

 Facsimiles for the HSLS:09 Second Follow-up interview, abbreviated interview, and reinterview

instruments;

 Transcript data request contacting materials and data elements (appendix F); and

 Financial aid records collection request contacting materials and data elements (appendix G).
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The HSLS:09 base-year data collection took place in the 2009–10 school year, with a randomly 

selected sample of fall-term 9th-graders in more than 900 public and private high schools with both 9th 

and 11th grades.1This fall 2009 cohort of 9th graders has been followed over time, with follow-ups in

spring 2012 and summer-fall 2013. Administrative records (such as high school transcripts) have also 

been collected. The basic components and key design features of HSLS:09 are summarized in exhibit A-1 

below, by wave of data collection:

Exhibit A-1. HSLS:09 Data Collection Components, by wave of data collection

Base

Year

1st

Follow-up

2013

Update

2nd

Follow-up

Sample Member Survey ◊ ◊ ◊ ◊

Sample Member Math Assessment ◊ ◊

Parent Survey ◊ ◊

School Counselor Survey ◊ ◊

School Administrator Survey ◊ ◊

Math Teacher Survey ◊

Science Teacher Survey ◊

High School Transcripts ◊

Postsecondary Transcripts ◊

Administrative Data (e.g., SAT, ACT, GED, CPS, NSLDS, 

NSC, Voting data) ◊ ◊

HSLS:09 data will allow researchers, educators, and policymakers to examine motivation, 

achievement, and persistence in STEM course-taking and careers. More generally, HSLS:09 data will 

allow researchers from a variety of disciplines to examine issues of college entry, persistence, and 

success, and how changes in young people’s lives and their connections with communities, schools, 

teachers, families, parents, and friends affect these decisions, including:

 academic (especially in math and science), social, and interpersonal growth;

 transitions from high school to postsecondary education, and from school to work;

 students’ choices about, access to, and persistence in math and science courses, majors, and 

careers;

 the characteristics of high schools and postsecondary institutions and their impact on student 

outcomes;

 family formation, including marriage and family development, and how prior experiences in and 

out of school correlate with these decisions; and

 the contexts of education, including how minority and at-risk status is associated with education 

and labor market outcomes.

 

1 Types of schools that were excluded from the sample based on the HSLS:09 eligibility definitions are described as part of the discussion of 

the target population in the HSLS:09 Base-Year Data File Documentation (see chapter 3, section 3.2.1), Ingels et al. (2011). See the same 

source for further information about the study sample design, including state-representative samples and base year student oversampling.
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A.1.b Legislative Authorization

HSLS:09 is authorized under the Education Sciences Reform Act (ESRA) of 2002 (20 U.S.C. § 

9543).

A.1.c Prior and Related Studies

In 1970, NCES initiated a program of longitudinal high school studies. Its purpose was to gather 

time-series data on nationally representative samples of high school students that would be pertinent to 

the formulation and evaluation of education polices. Starting in 1972, with the National Longitudinal 

Study of the High School Class of 1972 (NLS:72), NCES began providing education policymakers and 

researchers with longitudinal data that linked education experiences with later outcomes, such as early

labor market experiences and postsecondary education enrollment and attainment. The NLS:72 cohort of 

high school seniors was surveyed five times (in 1972, 1973, 1974, 1979, and 1986). A wide variety of 

interview data were collected in the follow-up surveys, including data on students’ family background, 

schools attended, labor force participation, family formation, and job satisfaction. In addition, 

postsecondary transcripts were collected.

Almost 10 years later, in 1980, the second in a series of NCES longitudinal surveys was launched, 

this time starting with two high school cohorts. High School and Beyond (HS&B) included one cohort of 

high school seniors comparable to the seniors in NLS:72. The second cohort within HS&B extended the 

age span and analytical range of NCES’s longitudinal studies by surveying a sample of high school 

sophomores. With the sophomore cohort, information became available to study the relationship between 

early high school experiences and students’ subsequent education experiences in high school. For the first 

time, national data were available showing students’ academic growth over time and how family, 

community, school, and classroom factors promoted or inhibited student learning. In a leap forward for 

education studies, researchers, using data from the extensive battery of cognitive tests within HS&B, were 

also able to assess the growth of cognitive abilities over time. Moreover, data were now available to 

analyze the school experiences of students who later dropped out of high school. These data became a rich 

resource for policymakers and researchers over the next decade and provided an empirical base to inform 

the debates of the education reform movement that began in the early 1980s. Both cohorts of HS&B 

participants were resurveyed in 1982, 1984, and 1986. The sophomore cohort was also resurveyed in 

1992. Postsecondary transcripts were collected for both cohorts.

The third longitudinal study of students conducted by NCES was the National Education 

Longitudinal Study of 1988 (NELS:88). NELS:88 further extended the age and grade span of NCES 

longitudinal studies by beginning the data collection with a cohort of eighth-graders. Along with the 
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student survey, it included surveys of parents, teachers, and school administrators. It was designed not 

only to follow a single cohort of students over time (as had NCES’s earlier longitudinal studies, NLS:72 

and HS&B), but also, by “freshening” the sample at each of the first two follow-ups, to follow three 

nationally representative grade cohorts over time (8th-, 10th, and 12th-grade cohorts). This provided not 

only comparability of NELS:88 to existing cohorts, but it also enabled researchers to conduct both crosssectional inter-cohort and longitudinal intra-cohort analyses of the data. In 1993, high school transcripts 

were collected. Students were interviewed again in 1994 and 2000, and in 2000–01 their postsecondary

education transcripts were collected.

The Education Longitudinal Study of 2002 (ELS:2002) was the fourth longitudinal high school 

cohort study conducted by NCES. ELS:2002 started with a sophomore cohort and was designed to 

provide trend data about the critical transitions experienced by students as they proceeded through high 

school and into postsecondary education or their careers. Student interviews and assessments in reading 

and mathematics were collected along with surveys of parents, teachers, and school administrators. In 

addition, a facilities component and school library/media studies component were added for this study

series. Freshening occurred at the first follow-up in 2004 to allow for a nationally representative cohort of 

high school seniors, which was followed by the collection of high school transcripts. A second follow-up 

was conducted in 2006, and a third follow-up in 2012 (with a postsecondary education transcript 

component in 2013).

These studies have investigated the education, personal, and vocational development of students, 

and the school, familial, community, personal, and cultural factors that affect this development. Each of 

these studies has provided rich information about the critical transition from high school to postsecondary

education and the workforce. HSLS:09 will continue on the path of its predecessors while also focusing 

on the factors associated with choosing, persisting in, and succeeding in STEM course-taking and careers.

A.2 Purpose and Use of Information Collection

HSLS:09 links to its predecessor longitudinal studies by addressing many of the same issues of 

transition from high school to postsecondary education and the labor force. At the same time, HSLS:09 

brings a new and special emphasis to the study of youth transition by exploring the paths that lead 

students to pursue and persist in courses and careers in the fields of science, technology, engineering, and 

mathematics (STEM). HSLS:09 is designed to measure math achievement gains in the first 3 years of 

high school, but also to relate tested achievement to students’ choice, access, and persistence of courses, 

college, and careers, especially in science, technology, engineering, and mathematics pipelines. The 

HSLS:09 assessment serves not just as an outcome measure, but also as a predictor of readiness to 
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proceed into college and, in particular, STEM courses and careers, while tested achievement in 

mathematics can also be used as a baseline covariate in multivariate longitudinal analyses. Interviews 

focus on factors that shape students’ decision-making about courses and postsecondary options, including 

what factors, from parental input to considerations of financial aid for postsecondary education, enter into 

these decisions.

There are several reasons the transition into adulthood is of special interest to federal policy and 

programs. Adolescence is a time of physical and psychological changes. Attitudes, aspirations, and 

expectations are sensitive to the stimuli that adolescents experience, and environments influence the 

process of choosing among opportunities. Parents, educators, and those involved in education policy 

decisions all share the need to understand the effects that the presence or absence of good guidance from 

the school, in combination with that from the home, can have on the educational, occupational, and social 

success of youth.

These patterns of transition cover individual and institutional characteristics. At the individual 

level, the study examines education attainment and personal development. In response to policy and

scientific issues, data have been gathered on the demographic and background correlates of education 

outcomes. By collecting extensive information from students, parents, school staff, and school records, it 

will be possible to investigate the relationship between home and school factors and academic 

achievement, interests, and social development at this critical juncture. Resources to assist in guiding 

parents and students through the college decision process, from information-seeking behaviors to filing 

financial aid forms, can be explored in terms of how they relate to college entry. Additionally, because the 

initial survey focused on 9th-graders, it also permits the identification and study of high school (and later, 

college) dropouts.

HSLS:09 is intended to be a general-purpose dataset; that is, it is designed to serve multiple policy

objectives. Policy issues studied through HSLS:09 include the identification of school attributes and 

processes associated with mathematics achievement, college entry, and career choice; postsecondary

access, choice, persistence, and attainment; the factors associated with dropping out of the education 

system; and the transition of different groups (for example, racial and ethnic, gender, and socioeconomic 

status groups) from high school to postsecondary institutions and the labor market, and especially into 

STEM curricula and careers. HSLS:09 will provide a strong basis for investigators to inquire into 

students’ attitudes, beliefs, expectancies, values, and goals. Researchers can investigate factors affecting 

risk and resiliency, gather information about the social capital available to sample members, inquire into 

the nature of student interests and decision-making, and delineate students’ curricular and extracurricular 
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experiences in both high school and higher education. HSLS:09 includes measures of school climate; each 

student’s native language and language use; student and parental education expectations; attendance at 

school; course and program selection; college plans, preparation, and information-seeking behavior; 

interactions with teachers and peers; as well as parental resources and support. The HSLS:09 data 

elements are designed to support research that speaks to the underlying dynamics and education processes 

that influence student achievement, growth, and personal development over time.

HSLS:09 is first and foremost a longitudinal study; hence survey items are chosen for their 

usefulness in predicting or explaining future outcomes as measured in later survey waves. Compared to its 

earlier counterparts, there are considerable changes to the design of HSLS:09 that will limit the ability to 

produce trend comparisons. There are two such limiting factors in particular. One is that there was no 

sample freshening in HSLS:09. In consequence, there is no representative spring senior cohort (or 

sophomore cohort), but rather a fall 9th grade cohort, unrepresentative of any other grade, followed over 

time. The second reason, closely related to the first, is that none of the data collection points in HSLS:09 

correspond with the collection points in the prior secondary longitudinal studies (e.g., NELS:88 at grades 

8, 10, and 12). At the same time, HSLS:09 and the prior studies alike deal with the same basic issues: the 

transition through high school and into the postsecondary world, represented primarily by education and 

work. Comparisons between HSLS:09 and the four earlier studies may be made at this higher level of 

generality. Comparisons cannot be made on the basis of data collections at the precise same grades (e.g., 

senior trends), since different collection points were used. The fact that precise grade-by-grade 

comparisons cannot be made is of consequence for HSLS:09 in that HSLS:09 has greater latitude in 

incorporating new interview items, given that the trend measurement requirement of asking the same 

thing in the same way as previous studies is no longer of strict relevance.

In the second follow-up main study, in addition to sample member interviews, college transcripts 

and financial aid student records will be collected from the postsecondary institutions attended by those 

HSLS:09 sample members who have enrolled in postsecondary education. The two data sources will 

address a range of issues concerning students’ enrollment and course taking patterns, progress and 

attainment in postsecondary education, and the types, sources, and amounts of student aid received across 

years of attendance.

Postsecondary Transcript Collection. As an official institution record, the postsecondary

transcript is a more reliable source of data regarding academic performance than is a student’s self-report. 

The transcript collection for HSLS:09, which will be designed like that conducted for ELS:2002 and 

BPS:04/09, will provide much-needed information on the course of study of today’s college students as 

they begin, leave, and re-enter postsecondary study and transfer between institutions. The combination of 
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transcripts and other study data collected through interviews, file matching, and record abstraction will 

afford researchers the opportunity to analyze paths taken by cohort members as they begin undergraduate 

education. Postsecondary transcripts provide a wealth of data on enrollment, including degree or 

certificate program, terms enrolled and course intensity when enrolled, and fields of study. Furthermore, 

transcripts provide coursetaking details including subjects taken and credits and grades earned. These data

provide important links between secondary academic performance, plans and expectations, and pathways 

into the workforce of the sample members.

Financial Aid Student Record Collection. Despite access to federal aid databases, a complete 

picture of all non-federal inputs into student financial aid has been lacking in the secondary longitudinal 

studies, constituting a severe limitation in the postsecondary years of the survey. Availability of financial 

aid is important at all points in the postsecondary process (initial access and choice, persistence, transfer, 

and ultimate educational attainment). The financial aid data records collected from the institutions 

attended by HSLS:09 sample members will greatly increase the analytic power of HSLS:09 – cumulative 

aid and debt, generally at a midpoint through postsecondary education, can be calculated with the 

availability of scholarship, fellowship, grant, and loan amount.

Additionally, two panel maintenance collections are planned. The first will take place in summer 

of 2015 for the main study sample, and a second panel maintenance collection may take place in early

2018 with the field test and main study samples in anticipation of another follow-up with this cohort.

A.2.a Content Justifications

Overview. This section contains justifications for the HSLS:09 Second Follow-up field test 

instrument, reflecting the main research objectives of the study overall, and for this specific round in 

particular. The draft field test interview has been included in Appendix E.

The second follow-up survey items serve to support the overall purposes of HSLS:09, which are to 

understand the factors (e.g., experiences, behaviors, attitudes, interactions with people) that influence 

students’ decision-making processes about postsecondary enrollment and coursetaking, and occupation 

goals, and to understand how these decisions evolve in the years after secondary school, ultimately

marking the transition to adult status (as seen in education attainment, career, family formation, etc.).

For those in (or ahead of) modal high school grade progression sequence (that is, those who 

completed high school by 2013, including early and on-time graduates), the prime foci of the interviews 

will be sub-baccalaureate attainment, labor market status of those who are working part- or full-time, 

postsecondary transfer, and postsecondary persistence. The second follow-up interview will also update 
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information on high school attainment for students who, as of the 2013 update, had dropped out, or were 

held back a grade or more, in their secondary schooling. At the time of the second follow-up, the 

HSLS:09 cohort will be similar to members of the first follow-up of the 2012-14 Beginning 

Postsecondary Students Longitudinal Study (BPS:12/14). BPS covers all postsecondary entrants, early

and late, while HSLS:09 does not include late entrants but provides a comparison group that is not in 

postsecondary education. Such comparison draws on the fact that those HSLS:09 cohort members who 

start postsecondary education the fall after modal high school graduation will have the same time spread 

between that time point and the HSLS:09 second follow-up survey as do BPS cohort members who 

started postsecondary education immediately after high school completion. In other words, both the BPS 

and the HSLS:09 immediate entrants are followed 3 years after first enrollment.

The draft HSLS:09 Second Follow-up interview appears as Appendix E of this submission. The 

primary research areas drive the survey instrument: (1) High School Attainment; (2) Postsecondary

Access and Choice; (3) Attainment of Sub-baccalaureate Credentials: (4) Postsecondary Education 

Transfer and Persistence; (5) Career Development; and (6) Labor Market Experience. Each of these areas 

shall be separately discussed. Some additional subthemes that are represented on the interview will also 

be mentioned: marriage and family formation and the college experience.

1. High School Attainment

While information on high school completion is available for on-time graduates, the high school 

completion status of the remainder of the cohort must be addressed again in the HSLS:09 Second Followup. Dropouts, and students who take extra time to complete secondary school, are of high policy interest.

Prior round nonrespondents also need to have their enrollment data updated. The prior secondary

longitudinal studies show large numbers of high school dropouts eventually achieving alternative 

credentials (such as the GED) or returning to high school, while others remain without high school 

completion or equivalency even eight years after their cohort’s modal graduation date. GED 

administrative records are also a possible source for this topic area, and have been collected for prior 

secondary longitudinal studies.

2. Access and Choice

Access to postsecondary education can be conceptualized in multiple ways, which are not 

necessarily mutually exclusive. Academic access, for example, is more limited for dropouts and for lowachieving students, while financial access speaks to the possible gaps between student resources and 

student aid programs. Access is also influenced by expectations and aspirations. Those with academic and 

financial access may choose to enroll in postsecondary education. Enrollment, in turn, is affected by
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factors that may enhance or inhibit choice: academic preparation (e.g., coursetaking, grades, and tested 

mathematics achievement); individual-level characteristics such as education and occupation or career 

aspirations or expectations; and family background characteristics such as family income, parental 

education, and educational expectations for their child.

Choice is sometimes characterized as the ability to attend an institution that is the best academic fit 

at an affordable price. Financial wherewithal is a key aspect of choice, not just in the sense of ability to 

pay, but also in terms of early perceptions of cost, which may affect both college preparation and the 

application process (which has been meticulously captured in the earlier rounds of HSLS:09). The degree 

of choice available to students affects the type and sector of postsecondary institutions attended (for 

example, 2-year versus 4-year public or private institutions); intensity of attendance (full- versus parttime); whether enrollment is at the “first choice” institution; and its location (urban, suburban, or rural; 

near home or distant). For students whose individual background and family resources enable a range of 

postsecondary education options, the concept of choice incorporates institutional characteristics such as 

the appeal of social and athletic environments and the academic prestige or ethos of a school.

3. Attainment of Sub-baccalaureate Credentials

The timing of the second follow-up does not provide a basis for studying baccalaureate attainment.

However, the 3-year post-graduation gap offers a window into attainment of 2-year degrees, 

postsecondary certificates, and certifications. As well, the timing provides an opportunity to study the 

transition from community college settings to 4-year programs. This is a research issue to be vigorously

pursued in the interview, and administrative data will be sought to further enhance the picture of subbaccalaureate attainment.

4. Transfer and Persistence

Persistence, staying the course until graduation or certification, is clearly of great importance to 

HSLS:09—although the timing of this measurement within the secondary longitudinal studies has been an 

issue. Historically in HS&B, NELS:88, and ELS:2002, a basis for studying persistence has not been 

provided in the first measurement point past high school (two years), but at the end of the study (around 

age 26 for NELS and ELS) with multiple postsecondary interview data points and continuous 

coursetaking data from the postsecondary transcripts. Here, HSLS:09 will once more prove its singularity

in the study series, given the 3-year post-graduation gap and the possibility of a postsecondary transcripts 

collection option. As a result, HSLS:09 may be looked to for providing highly timely and excellent 

information on early persistence in baccalaureate programs, and even better information about subbaccalaureate persistence and attainment (both in school, and in major or field of study). The same may
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be the case for understanding progress through the curriculum and, relatedly, transfer and institutional 

mobility.

5. Career Development (Major, Field of Study, and Employment History as Pathways into 

Career Formation)

Career development is a natural focus for any longitudinal social capital study of young people, 

but it is given special salience by the HSLS:09 stress on STEM careers. Career status can be elicited from 

the context of the current job, and status and plans can also be represented through questions about the 

occupation or job expected at age 30. A perhaps richer tack to be considered for the construct of career 

status or plans is to be found in social-cognitive career theory. The field test will give due consideration to 

testing social cognitive measures for the HSLS:09 Second Follow-up. Based on the notion that people 

learn by observing others, social cognitive scales of the education domain (or of occupation/the work 

place) can be used to measure several key constructs, some that may complement and build on HSLS:09 

base year data: self-efficacy, outcome expectations, occupational interests, work supports and barriers, 

domain satisfaction, and persistence intentions among them. Social cognitive career theory measures were 

developed for and included in the final follow-up of ELS:2002. Such measures would be stronger on 

HSLS:09 Second Follow-up because they are ideally longitudinal: the outcomes of these predictors could 

be captured in future rounds.

6. Labor Market Experience

Labor market pathways of high school graduates and dropouts who do not participate in 

postsecondary education can be captured in the second follow-up. Some of the effects of job-related 

training and adult education can also be investigated at this juncture in HSLS:09. Recent history has seen 

a growing consensus about the sophisticated skill requirements of the “21st century workforce.” Along 

with the formal education training of workers, the new flexible workforce will need workers who are 

continuously learning new skills and competencies, some of which may be validated with formal 

professional licensure and certification. While postsecondary education and labor experiences are prime 

foci, it should be remembered that NELS:88 and ELS:2002 show that, at ages 20 and 26, a substantial 

number of student sample members (sometimes in the range of 10 percent) reported that they were 

engaged in neither school nor work for pay. Second follow-up items must also capture the activities and 

experiences of these individuals, some of whom are unemployed or stay-at-home parents.

7. Related Sub-themes: Marriage, Family; College Experience

Marriage and family formation is another marker of the transition to adulthood. Though this subtheme warrants less interview space than the work and postsecondary education question series, it remains 
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important to gather the basic facts of domestic arrangements, keeping in mind that work and education 

opportunities may in part be influenced or conditioned by constraints such as child care, or may be 

positively or negatively supported by marriage.

College Experience: Since this round marks the data collection in which most cohort members 

will be students in a postsecondary setting, it will be the preferred time to ask questions about the college 

experience. Just as students are influenced by their high school education experience, postsecondary 

settings exert peer and instructor influence, and reflect academic climate as well. The extent of students’ 

engagement and time spent in college activities and its perceived contributions to students’ overall 

development of knowledge and skills may also relate to students’ subsequent career development and 

other life course outcomes. The college experience is a research area that may well support substantial 

numbers of questions that are new to the secondary longitudinal studies series.

Postsecondary Transcripts and Financial Aid Records. The lists of data elements for both the 

postsecondary transcript collection and the financial aid record collection can be found in Appendix F and 

G, respectively. The HSLS:09 PETS will include the same data elements as the previously-approved 

PETS in ELS:2002, B&B:08/09, and BPS:04/09, including: case information, schools and terms, 

academic honors, tests, degrees and majors, and courses. The data elements for the financial aid record 

collection will be the same as those collected for the ELS:2002 Financial Aid Feasibility Study and the 

National Postsecondary Student Aid Study (NPSAS). Potential research topics are discussed below.

Postsecondary Transcripts. Researchers have found, in analyses of HS&B and NELS:88 PETS 

(e.g., Adelman 20062), that “academic intensity of the student’s high school curriculum” counts 

importantly in providing momentum toward completing a bachelor’s degree. Transcripts provide unique, 

empirical data on student course-taking, performance, transfer, academic momentum and intensity, fields 

of study, and degree outcomes. Combined with student interview and high school transcript data, 

postsecondary transcript data can create a rich analytic resource for the study of postsecondary education.

The HSLS:09 PETS is the sixth in a series of postsecondary education transcript studies of high 

school cohorts; the first (NLS:72) took place in 1984, and was followed by HS&B sophomore cohort 

(1993), HS&B senior cohort (1986), NELS:88 (2000), and ELS:2002 (2012). Postsecondary education 

transcript studies have also been undertaken in connection with BPS and Baccalaureate and Beyond 

(B&B) longitudinal studies. A fundamental difference is that BPS and B&B are grounded in a nationallyrepresentative sample of postsecondary institutions (NPSAS) while the high school studies are based on a 

 

2 Adelman, C. (2006). “The Toolbox Revisited: Paths to Degree Completion from High School Through College” Washington, 

DC: US Department of Education.
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grade cohort-based secondary school sample. In addition, BPS captures all students entering 

postsecondary education, while the high school studies miss late entrants. Likewise, B&B is 

representative of baccalaureate recipients, while studies such as HSLS:09 and ELS:2002 (which lack both 

late entrants and late completers) are not.

While HSLS:09 cannot produce national estimates of postsecondary transfers or address the 

pathways of late entrants, its link to high school data provides rich information on the antecedents and 

pathways of individuals entering postsecondary education fairly promptly after high school.

Some research topics that can be addressed with the HSLS:09 transcript data include:

 Academic preparation – As a longitudinal study, HSLS:09 is positioned to provide data on 

secondary school preparation and postsecondary outcomes. The combined interview and high 

school transcript data offer insight on the academic preparation of students, including the courses 

they took and their performance. Postsecondary transcripts will add data on subsequent coursetaking and performance, creating opportunities to study the student academic experience over 

time.

 Transfer – By collecting transcripts from all postsecondary institutions sample members are 

known to have attended, the study enables analysis of the movement of students and credits 

between institutions. Example research questions include: How prevalent is student transfer 

between institutions, including co-enrollment, and how are credits transferred between 

institutions? How does transfer impact student outcomes?

 Course-taking – Analysis of transcripts across the student sample provides insights on 

postsecondary education offerings and student course taking. Frequencies of courses in particular 

topic areas can be examined, such as STEM, occupational, or remedial courses. Course-taking 

data can be combined with data on student program type, level (e.g. freshman), degree attainment, 

school sector, and a variety of other variables to gain insight on how course-taking varies across 

student and institution types. Additional course data, such as credits earned or attempted and grade 

point averages in selected topic areas can give further insights on performance and progress of the 

study population. Example research questions include: How does course taking vary for students 

at public, private non-profit, and private for-profit institutions, or at 4-year, 2-year, and less-than2-year institutions? How does course-taking influence persistence and other student outcomes?

 Academic performance - Transcripts provide more detailed data on academic performance than 

can be collected from any other source. Grade data from transcripts can be used to examine 

performance in specific subject areas or in selected time periods (e.g. 1st year students). Grade data 

can be combined with degree attainment, stop-out, transfer, or interview data such as employment 

and income to create a more detailed picture of how academic performance relates to progress and 

student outcomes.

 Credit accumulation – Similar to academic performance, transcripts provide a unique opportunity 

to analyze student credit accumulation. Credit accumulation can be measured across institutions 

and across time, enabling analysis of concepts such as enrollment intensity (i.e. full-time or parttime enrollment) and time to degree. How much does part-time enrollment delay degree 

completion, and does it decrease the likelihood of earning a degree? Transcript data provide an 

additional dimension to the analysis of time to degree and persistence, introducing the added detail 

of how credits were earned during the time a student was enrolled.
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 “Events” – Transcripts provide empirical evidence of events in postsecondary enrollment such as 

stop-outs, transfers, summer or dual enrollment periods, and other phenomena that are difficult to 

capture or measure solely with self-reported data. Patterns of attendance, such as swirling or 

moving from 2-year to 4-year institutions can also be analyzed.

Financial Aid Records. As stated above, the content is extracted from the set of financial aid data 

elements developed for ELS:2002 and NPSAS. Availability of financial aid is important at all points in 

the postsecondary process (initial access and choice, persistence, transfer, and ultimate educational 

attainment). More detail pertaining to item justification can be found in Appendix G.

Additional data for the HSLS:09 sample will be obtained from a variety of administrative data 

sources. These include queries of the Central Processing System (CPS), the National Student Loan Data 

System (NSLDS) containing Pell loan and grant files, the GED testing service, the National Student 

Clearinghouse (NSC), vendors of national undergraduate student admission tests including ACT and SAT 

scores, and vendors of voter registration data. The security procedures in place for the linkages to 

administrative data are presented in appendix B, and a description of the data security language for vendor 

contracts sources is provided in appendix C.

A.3 Use of Improved Information Technology

The website for data collection will reside on NCES’ SSL-encrypted servers. HSLS:09 will use 

web-based interviews across two modes of data collection, self-administered surveys and computerassisted telephone interviewing (CATI), and will be made mobile-friendly to allow participants to 

complete the full survey on a tablet or smartphone. On a nightly basis, the data collection contractor, RTI, 

will download interview data, in batches, to its Enhanced Security Network (ESN) via a secure web 

service. Once in the ESN, data will be cleaned and undergo quality analysis.

In the main study, data will be collected from the postsecondary institutions attended by HSLS:09 

sample members. These institutions will be identified as part of the 2016 main study survey. For the 

transcript and financial aid records collections to be conducted in 2017, institutions will receive an 

announcement in which institution staff will be invited to access the NCES postsecondary data portal 

website where they will find information on the purposes of the collections, along with forms and 

instructions, FAQs, endorsements, legal authority, and how to contact project staff. To access restricted 

pages containing confidential information, the user will be required to log in by entering an assigned ID 

number and password. Once each task is completed, institution staff will no longer be able to access it, 

but a status screen will indicate which stages of data collection have been concluded.
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A.3.a Postsecondary Transcripts: HSLS:09 PETS

Information technology will be employed in the collection of postsecondary transcripts and course 

catalogs from the institutions attended by HSLS:09 sample members. As a first step, RTI will collect 

course catalogs for and postsecondary transcripts from institutions where HSLS:09 cohort members were 

enrolled. College Source Online will be the initial source of catalogs. Any institutions for which catalogs 

cannot be obtained in that manner will be asked to provide the course catalogs directly to RTI via the 

means of their choice, such as email, postal mail, or other methods. Postsecondary transcripts will be 

requested from all institutions known to have been attended by the sample member since high school, and 

can be transmitted via upload, electronic fax, and other secure means (section B.3.a includes a description 

of each method). The first phase comprises a small sample of the institutions reported by sample members 

and will serve as a pilot to test systems and procedures. The second phase involves collecting data from 

the rest of the institutions, and the third phase reviewing postsecondary transcripts collected during phase 

one and two, identifying new student-institution linkages, and following up with the new institutions so 

identified.

A keying and coding system (KCS) will be used for data entry of the transcripts received. The 

KCS application, developed by RTI, includes data entry fields corresponding to the key data elements to 

be collected from transcripts. Following quality control and data cleaning processes, data collected from 

transcripts are assembled into data files for subsequent analysis.

A.3.b. Financial Aid Records Collection: HSLS:09 FAR

To ensure the efficiency, quality, and ease of the financial aid student records collection, HSLS:09 

FAR will use a web-based application. Similar to what is used on NPSAS studies, multiple options will be 

offered to an institution for providing student data, including: (1) uploading electronic (.csv) files to a 

secure web site; (2) downloading an Excel workbook from the web site, then uploading the completed file 

to the site; and (3) use of a web-based data entry interface.

An online video tutorial will be available to show users exactly how to navigate through the 

application and help screens will provide users with more in-depth explanations of the required items. The 

web-based application will allow error checking to be performed immediately by institution staff. An 

important feature of the online application is that different institution staff can complete portions of the 

required data entry and can complete the data entry in multiple sessions. These features reduce user 

burden while ensuring that the most accurate data are collected.
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A.4 Efforts to Identify Duplication and Use of Similar Information

Since the inception of its secondary education longitudinal studies program in 1970, NCES has 

consulted with other federal offices to ensure that the data collected in this important series of longitudinal 

studies do not duplicate the information from any other national data sources within the U.S. Department 

of Education or other government agencies. In addition, NCES staff regularly consult with nonfederal 

associations such as the College Board, American Educational Research Association, the American 

Association of Community Colleges, and other groups to confirm that the data to be collected through this 

study series are not available from any other sources. These consultations also provided, and continue to 

provide through the HSLS:09 Technical Review Panel, methodological insights from the results of other 

studies of secondary and postsecondary students and labor force members, and they ensure that the data 

collected through HSLS:09 will meet the needs of the federal government and other interested agencies 

and organizations. Other longitudinal studies of secondary and postsecondary students (i.e., NLS:72, 

HS&B, NELS:88, ELS:2002) have been conducted by NCES in the past. HSLS:09 builds on and extends 

these studies rather than duplicating them.

First, current efforts explicitly complement the redesign of NPSAS and BPS with the 

instrumentation and design of HSLS:09. Second, design articulation with prior NCES secondary

longitudinal studies (though more limited for HSLS:09 than for prior secondary longitudinal studies) also 

show coordination, not duplication. These earlier studies were conducted during the 1970s, 1980s, 1990s, 

and the early 2000s and represent education, employment, and social experiences and environments 

different from those experienced by the HSLS:09 student sample. In addition to extending prior studies 

temporally as a time series, HSLS:09 extends them conceptually. Unlike preceding secondary

longitudinal studies, HSLS:09 provides data that are necessary to understand the role of different factors 

in the development of student commitment to attend higher education and then to take the steps necessary

to succeed in college (taking the right courses, taking courses in specific sequences, etc.). Further, 

HSLS:09 focuses on the factors associated with choosing and persisting in mathematics and science 

course-taking and STEM careers. These focal points present a marked difference between HSLS:09 and 

its predecessor studies.

While National Science Foundation studies such as the Survey of Recent College Graduates cover 

some of the same ground as the postsecondary rounds of HSLS:09, the NSF effort is more narrowly 

focused, does not follow a nationally representative sample of secondary school students, and thereby

does not provide measures of outcomes of secondary education experiences. Additionally, NSF was 

actively involved in the design stage of HSLS:09 and provided financial assistance for augmentations of 
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certain state public high school samples so as to provide a robust and representative basis for analyses 

with a subset of states.

The only other dataset that offers so large an opportunity to understand the key transitions into 

postsecondary institutions or the world of work are the Department of Labor’s (Bureau of Labor 

Statistics) National Longitudinal Survey of Youth 1979 and 1997 cohorts (NLSY79, NLSY97). However, 

the NLSY youth cohorts represent temporally earlier cohorts than HSLS:09. There are also important 

design differences between NLSY79/ NLSY97 and HSLS:09 that render them more complementary to 

each other rather than duplicative. NLSY is a household-based longitudinal survey, while HSLS:09 is 

school-based. For both NLSY cohorts, Armed Service Vocational Aptitude Battery (ASVAB) test data 

are available, but there is no longitudinal high school achievement measure. Although NLSY97 also 

gathers information from schools (including principal and teacher reports and high school and 

postsecondary transcripts), given its household sampling basis, it cannot study school processes in the 

same way as HSLS:09. Any given school contains only one to a handful of NLSY97 sample members, a 

number that constitutes neither a representative sample of students in the school nor a sufficient number to 

provide within-school estimates. Thus, although both studies provide important information for 

understanding the transition from high school to the labor market, HSLS:09 is uniquely able to provide 

information about education processes and within-school dynamics and how these affect both school 

achievement and ultimate labor market outcomes, including outcomes in science, technology, 

engineering, and mathematics education and occupations. On the NLSY97 side of the equation, the NLSY 

is uniquely able to construct continuous labor market event histories for decades past graduation.

A.5 Impact on Small Businesses or Other Small Entities

Target respondents for HSLS:09 Second Follow-up interviews are individuals and the data 

collection activities will not involve burden to small businesses or entities. For the main study 

postsecondary transcript and financial aid record collections, some small for-profit schools and other 

small public and private schools will be contacted. Burden on these schools will be minimized by working 

closely with a school-appointed coordinator (e.g., the registrar) before the start of the data collection to 

identify the format in which records are kept and transmitted. To further minimize burden, course catalogs 

will be collected from a public online resource when available. To accommodate any constraints imposed 

by record-keeping systems, schools will be offered alternative methods of providing the requested 

transcripts and financial aid student records as described above in section A.3.
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A.6 Consequences of Collecting the Information Less Frequently

Exhibit A-2 below documents the periodicity of HSLS:09:

Exhibit A-2. Longitudinal design for the HSLS:09 ninth-grade cohort: 2009–25

Recent education and social welfare reform initiatives, changes in federal policy concerning 

postsecondary student support, and other interventions necessitate frequent studies. Repeated surveys are 

also necessary because of rapid changes in the secondary and postsecondary education environments and 

the world of work. Indeed, arguably, longitudinal information provides better measures of the effects of 

program, policy, and environmental changes than would multiple cross-sectional inter-cohort studies.

The student follow-ups of HSLS:09 are less frequent than the 2-year interval employed with 

HS&B, NELS:88, and ELS:2002. The first follow-up took place at 2.5 years after the base year, and the 

second follow-up will take place 3 years after the first follow-up. In the 2013 update, data were collected 

at the modal timepoint of high school graduation and a high school transcript study was conducted soon 

after the summer following graduation to provide continuous coursetaking data for all on-time or early

completers. By following up at the end of the students’ junior year, researchers are able to measure 

achievement gain and postsecondary planning information. Collecting the postsecondary update in 

summer 2013 (directly after most students’ 12th grade year) and high school transcripts in fall 2013 

minimized burden on schools and respondents, while also allowing for further inter-cohort comparability
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with the main transition themes of the prior studies. The second follow-up is scheduled to occur in the 

third year after high school (spring 2016, to be field-tested in 2015), which is not on track with the timing 

of the predecessor studies. The three-year gap, however, offers better articulation with BPS, and facilitates 

getting sub-baccalaureate attainment data collected in a timely fashion and in great detail. Despite the 

changes in grade cohorts and data collection time points for the first three rounds, general trends will still 

be measurable, because the same key transitions, albeit with slightly different data collection points and 

content, will be captured with the HSLS:09 data.

A.7 Special Circumstances Relating to Guidelines of 5 CFR 1320.5

All data collection guidelines in 5 CFR 1320.5 are being followed. No special circumstances of 

data collection are anticipated.

A.8 Consultations Outside NCES

A panel of highly qualified substantive and methodological experts were invited to provide advice 

about the design and conduct of the HSLS:09 Second Follow-up study. The first meeting with the 

HSLS:09 Technical Review Panel (TRP) was held on October 15th and 16th, 2014 and included ten nonfederal panelists as well as members of NCES, other offices within the U.S. Department of Education, and 

the federal government. A second TRP meeting is planned for summer-fall 2015 to obtain feedback 

regarding plans for the main study design. TRP panelists are listed in Attachment C.

In addition, suggestions on specific items for the Lesbian, Gay, Bisexual and Transgender (LGBT) 

domain were provided by content experts from members of the Gay, Lesbian & Straight Education 

Network (GLSEN), The Fenway Institute, and the Gender Identity in US Surveillance (GeniUSS) group. 

Items came from a variety of sources, include the CDC's Youth Risk Behavior Survey (YRBS), the MA 

Department of Public Health's Youth Health Survey, and the NICHD's National Longitudinal Survey of 

Adolescent Health, among others. Further consultation was also sought with the CDC on these questions.

A.9 Provision of Payment or Gift to Respondents

Incentives are proposed as part of the field test data collection plan to encourage response and to 

minimize nonresponse through refusal conversion. Incentives are also intended to help increase study

participation from previously non-responding sample members. The use of incentives provides significant 

advantages to the government in terms of increased overall response rates and timely data collection, 

which in turn, result in decreased data collection costs and more complete data. The proposed incentive 

for completed interviews in the second follow-up field test is an average of $35 per interview. The Tests 
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of Procedures and Methods section of the Supporting Statement Part B document (section B.4) discusses 

in detail the plans for using incentives as part of a responsive design.

In the main study, institutions will be reimbursed for the cost of preparing and sending transcripts 

at the school's standard rate. If additional costs are incurred by the schools, such expenses will be 

reimbursed to the extent that they are reasonable and properly documented. Based on a similar 

postsecondary transcript collection conducted for ELS:2002, it is expected that approximately 20

institutions will request and receive reimbursement for expenses for approximately 360 transcripts at an 

average cost of $7 per transcript, and an average reimbursement of $126 for those institutions. For the 

FAR collection, it is expected that approximately 90 institutions will request and receive reimbursement 

at an average cost of $200 per institution.

The 2015 panel maintenance will consist of a mailing to each sample member and his or her 

parent/guardian asking that they log onto the survey website to update contact information or that they

complete a hardcopy address update (see appendix D). Sample members will be offered a $10 incentive 

for updating their contact information. Our recent experience has shown that offering such an incentive is 

an effective means of increasing panel maintenance response. For example, sample members in ELS:2002

were offered $10 to update their contact information during the 2011 panel maintenance period, and 

updates for approximately 29 percent of sample members were received. A $10 incentive was recently

approved3for HSLS:09 for the 2014 panel maintenance. Estimates of response burden are developed from 

experience with the previous HSLS:09 panel maintenance and from other education longitudinal studies 

(e.g., ELS:2002, NELS:88).

A.10 Assurance of Confidentiality Provided to Respondents

NCES assures participating individuals that all identifiable information collected as part of the 

HSLS:09 study may be used only for statistical purposes and may not be disclosed, or used, in identifiable 

form for any other purpose except as required by law [Education Sciences Reform Act of 2002 (ESRA 

2002), 20 U.S.C. § 9573]. HSLS:09 data security and confidentiality protection procedures are in place to 

ensure that RTI and its subcontractors comply with all privacy requirements, including:

 The Statement of Work of this contract;

 Privacy Act of 1974 5 U.S.C. § 552(a);

 The U.S. Department of Education Incident Handling Procedures (February 2009);

 

3 Approved in April 2013 (OMB# 1850-0852 v.11 & 12).
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 The U.S. Department of Education General Handbook for Information Technology Security

General Support Systems and Major Applications Inventory Procedures (March 2005);

 The U.S. Department of Education, ACS Directive OM: 5- 101, Contractor Employee 

Personnel Security Screenings.

 Family Educational Rights and Privacy Act of 1974, 20 U.S.C. § 1232(g);

 ESRA 2002, 20 U.S.C. § 9573; and

 All new legislation that impacts the data collected through this contract.

To further ensure that confidentiality is appropriately maintained at all times, vendors who assist 

in locating and tracing sample members will be required to follow procedures that safeguard personally 

identifying information. RTI’s vendor contracts outline requirements for information security policies and 

assessments, security awareness training, physical and environmental security, monitoring, and access 

control. They also specify the means by which information may be transmitted between RTI and the 

contractor.

Additionally, RTI will comply with the Department’s IT security policy requirements as set forth 

in the Handbook for Information Assurance Security Policy and related procedures and guidance as well 

as IT security requirements in the Federal Information Security Management Act (FISMA), OMB 

Circulars, and the National Institute of Standards and Technology (NIST) standards and guidance. All 

data products and publications will also adhere to the NCES Statistical Standards, as described at the 

website: http://nces.ed.gov/statprog/standards.asp.

The HSLS:09 procedures for maintaining confidentiality include notarized nondisclosure 

affidavits obtained from all personnel who will have access to individual identifiers; personnel training 

regarding the meaning of confidentiality; controlled and protected access to computer files; built-in 

safeguards concerning status monitoring and receipt control systems; and a secure, staffed, in-house 

computing facility. HSLS:09 follows detailed guidelines for securing sensitive project data, including, but 

not limited to: physical/environment protections, building access controls, system access controls, system 

login restrictions, user identification and authorization procedures, encryption, and project file 

storage/archiving/destruction.

There are security measures in place to protect data during file matching procedures described in 

section 3. NCES has a secure data transfer system, which uses Secure Socket Layer (SSL) technology, 

allowing the transfer of encrypted data over the Internet. The NCES secure server will be used for all 

administrative data sources with the exception of the NSC which has its own secure FTP site. All data 

transfers will be encrypted using FIPS 140-2 validated encryption tools.
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Furthermore, the Department has established a policy regarding the personnel security screening 

requirements for all contractor employees and their subcontractors. The contractor must comply with 

these personnel security screening requirements throughout the life of the contract. The Department 

directive that contractors must comply with is OM:5-101, which was last updated on 7/16/2010. There are 

several requirements that the contractor must meet for each employee working on the contract for 30 days 

or more. Among these requirements are that each person working on the contract must be assigned a 

position risk level. The risk levels are high, moderate, and low based upon the level of harm that a person 

in the position can cause to the Department’s interests. Each person working on the contract must 

complete the requirements for a “Contractor Security Screening.” Depending on the risk level assigned to 

each person’s position, a follow-up background investigation by the Department will occur.

Study notification materials sent to sample members will describe the voluntary nature of 

HSLS:09 and convey the extent to which respondent identifiers and all responses will be kept 

confidential. Similarly, the scripts to be read by telephone staff will be very specific in the assurances 

made to respondents and contacts. Contacting materials are presented in appendix D. The following 

confidentiality language is provided in the study brochure that is supplied to all sample members:

The High School Longitudinal Study of 2009 (HSLS:09) Second Follow-Up is conducted 

under the authority of the Education Sciences Reform Act (ESRA) of 2002 (20 U.S.C. § 

9543), which authorizes NCES to collect and disseminate information about education in 

the United States.

NCES is required to follow strict procedures to protect personal information in the 

collection, reporting, and publication of data. All individually identifiable information 

supplied by individuals or institutions may be used only for statistical purposes and may

not be disclosed or used in identifiable form for any other purpose, except as required by

law (20 U.S.C. § 9573).

Data security procedures for HSLS:09 are reviewed and approved by NCES data security

staff. Your answers are secured behind firewalls and are encrypted during internet 

transmission using Secure Sockets Layer (SSL) protocol. All data entry modules are 

password protected and require the user to log in before accessing confidential data. 

Project staff is subject to large fines or imprisonment if individual responses are disclosed.

Regarding file matching with administrative sources, the Family Educational Rights and Privacy 

Act (FERPA) (34 CFR Part 99) allows the disclosure of information without prior consent for the 

purposes of HSLS:09 according to the following excerpts: 34 CFR § 99.31 poses the question: “Under 

what conditions is prior consent not required to disclose information?” and explains in 34 CFR § 99.31(a)

that “An educational agency or institution may disclose personally identifiable information from an 

education record of a student without the consent required by §99.30 if the disclosure meets one or more” 

of several conditions. These conditions include, at 34 CFR § 99.31(a)(6)(i):
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“The disclosure is to organizations conducting studies for, or on behalf of, educational agencies or 

institutions to:

(A) Develop, validate, or administer predictive tests;

(B) Administer student aid programs; or

(C) Improve instruction.”

In addition, 34 CFR § 99.31(a)(6)(v) specifies: “For the purposes of paragraph (a)(6) of this 

section, the term organization includes, but is not limited to, Federal, State, and local agencies, and 

independent organizations.”

All three parts of 34 CFR § 99.31(a)(6)(i) apply to HSLS:09. The purpose of HSLS:09 is to create 

a research data set for a cohort of ninth-graders that brings together information about academic 

achievement in high school and subsequent participation in postsecondary education along with federal, 

state, and private financial aid programs. HSLS:09 also gathers background and demographic data to form 

the context for the outcome variables. The resulting data set allows research and policy analysts to address 

basic issues about the relationship between high school experiences and participation in postsecondary

education and the labor market. The data set can be used for, or on behalf of, educational agencies or 

institutions to accomplish activities (A), (B), and (C).

In 34 CFR § 99.31 (a)(6)(iii), FERPA further specifies that such disclosure may only occur if 

“[the] study is conducted in a manner that does not permit personal identification of parents and students 

by individuals other than representatives of the organization” and “[the] information is destroyed when no 

longer needed for the purposes for which the study was conducted.”

Appendix F includes a Family Educational Rights and Privacy Act Fact Sheet, which provides

institutions with the text of the FERPA requirements. The Fact Sheet includes highlighted passages that 

indicate the sections that authorize the transcript and financial aid records collections, and will be 

included in the packet sent to all institutions from which student data are requested.

Additionally, the study, including the administrative data linkage, qualifies for a 45 CFR 46 

waiver of consent based on the following factors:

 There is minimal risk to the participants. There is no physical risk and only minimal risk 

associated with linkage of data to sample members. The public-use and restricted-use data, 

prepared as part of the contract with RTI, will not include SSNs, even though these numbers are 

used for the linkage. Data will undergo disclosure avoidance analysis and disclosure treatment 

steps to further reduce the risk.

 The waiver will not affect the rights and welfare of the subjects. The voluntary nature of the study

is emphasized to sample members. Public-use and restricted-use data are only used for research 

purposes and lack direct individually-identifying information. The data are further protected 

through disclosure avoidance procedures approved by the NCES Disclosure Review Board.
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 Whenever appropriate, subjects will be provided with additional pertinent information after they

have participated. For each round of the study, information about prior rounds and the nature of 

the study is made available to sample members.

 The study cannot be conducted practicably without the waiver. To obtain written consent from 

sample members, multiple forms would have to be sent to the sample members with multiple 

follow-up telephone and in-person visits. This process would add weeks to the data collection 

process and is not feasible from a time standpoint. Additionally, the value of these data would be 

jeopardized from a nonresponse bias perspective.

 The potential knowledge to be gained from the study is important enough to justify the waiver. 

These linked data for HSLS:09 will provide invaluable data to researchers and education policy

makers about access to and persistence in postsecondary education and the early employment 

activities of young adults in the years beyond high school. Rather than ask sample members 

certain data elements (e.g. financial aid received, admissions test scores) these data will be 

obtained through matches to administrative records which will yield more accurate and complete 

data.

A data security plan (DSP) for HSLS:09 was approved by the IES Disclosure Review Board chair, 

and will be updated for the second follow-up. The HSLS:09 plan represents best-practice survey systems 

and procedures for protecting respondent confidentiality and securing survey data.

A.11 Justification for Sensitive Questions

The HSLS:09 Second Follow-up survey will include questions about earnings, assets, and debts in 

order to construct socioeconomic status variables and to calculate need for financial aid for those who 

have pursued postsecondary education. The Office of Civil Rights is seeking to better understand LGBT 

students who have been a target of bullying; to help address this, the HSLS:09 survey will include 

questions on sexual orientation and gender identity. Respondents are assured that all responses are 

voluntary.

A.12 Estimates of Annualized Burden Hours and Their Cost to Respondents

Estimates of response burden for the HSLS:09 Second Follow-up data collections are shown in 

Exhibits A-3. Estimates of survey response burden are based on estimates developed from experience 

with the base-year and first follow-up HSLS:09 interviews and experience on other education longitudinal 

studies (e.g., ELS:2002, BPS:12/14).

The response time for institutions participating in transcript collection is expected to vary

depending on the number of sampled students who attend the institution and the method selected for 

transmitting the transcripts. Institutions will be offered five different methods for providing responses 

including uploading data to the secure study website and sending data to a secure electronic fax server 

(section B.3 includes a description of each method; fax transmittal sheets may be found in appendix F). It 
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is expected that some of the transcripts collected will indicate enrollment at additional institutions.

Transcripts from any additional institutions identified in the review of transcripts will also be collected.

There are three methods of data collection available for providing student financial aid records 

data, one involves keying directly into a secure Web application and two involve preparing data and then 

uploading them to the website (section B.3 includes a description of each method). The estimated average 

time to provide financial aid records is approximately 3.3 hours per institution.

Also included are the estimates for panel maintenance which will be conducted in summer 2015 

with the main study sample, and a planned panel maintenance that may take place in early 2018 with the 

field test and main study samples in anticipation of an additional follow-up study in 2025.

Exhibit A-3. Estimated Burden for HSLS:09 Second Follow-up

Data collection activity Sample Expected 

response rate

Number of 

respondents

Number of 

responses

Average 

burden per 

response

(minutes)

Total 

burden 

(hours)

Survey and address data collection from individuals

Field test interview 1,100 64% 704 704 35 411

Field test reinterview 100 50% 50 50 10 8

Main study interview 23,316 92% 21,451 21,451 35 12,513

Main study sample panel maintenance 2015 23,316 20% 4,663 4,663 5 389

Field test sample panel maintenance 2018 1,100 20% 220 220 5 18

Main study sample panel maintenance 2018 23,316 20% 4,663 4,663 5 389

Field test totals 5,367 5,417 808

Records data collection from institutions

Postsecondary Transcript collection 3,800 85% 3,230 3,230 30 1,615

Financial Aid Record collection 3,800 85% 3,230 3,230 198 10,659

Records collections totals 3,230 6,460 12,274

Note: The current request for OMB approval is only for the field test study burden and the main study sample panel maintenance in 2015.

The total estimated cost to individual respondents is $14,574, which represents the 808 burden 

hours times an hourly rate of $18.04. The hourly rate was obtained by taking the average of the median

weekly earnings of full-time wage and salary workers4among high school graduates with no college and 

individuals with some college or an associate’s degree.

 

4

Taken from Table 5 - Quartiles and selected deciles of usual weekly earnings of full-time wage and salary workers by 

selected characteristics, 3rd quarter 2014 averages, not seasonally adjusted. http://www.bls.gov/news.release/pdf/wkyeng.pdf.
Supporting Statement Request for OMB Review (SF83I) A. Justification

25

A.13 Estimates of Total Annual Cost Burden to Respondents

There are no capital, startup, or operating costs to respondents for participation in the project. No 

equipment, printing, or postage charges will be incurred.

A.14 Annualized Cost to the Federal Government

Estimated costs to the federal government for HSLS:09 are shown in Exhibits A-4a and A-4b. The 

estimated costs to the government for data collection for the field test are presented separately. Included 

in the contract estimates are all staff time, reproduction, postage, and telephone costs associated with the 

management, data collection, analysis, and reporting for which clearance is requested.

Exhibit A-4a. Total Costs to NCES

Costs to NCES Amount

Total HSLS:09 second follow-up costs $16,755,907 

Salaries and expenses $300,000 

Contract costs $16,455,907 

Field test (2015) $2,435,026 

Salaries and expenses $150,000 

Contract costs $ 2,285,026 

Main study (2016) $14,320,881 

Salaries and expenses $150,000 

Contract costs $ 14,170,881 

NOTE: Field test costs represent Task 3 and two-fifths of Task 1 (representing two of the five years of the contract). Of the HSLS:09 

contract; base-year main study costs include tasks 2, 4, 5, 6, and three-fifths of Task 1.

Exhibit A-4b. Total Contract Costs 

Task 1 - Management $ 1,367,965 

Task 2 - Panel Maintenance for HSLS: 09 Second Follow-Up $ 569,092 

Task 3 - Field Test (FT) $ 1,737,840 

Task 4 – Main Study Data Collection $ 6,759,209 

Task 5 - Student Financial Aid Records Collection $ 2,218,028 

Task 6 - Postsecondary Transcript Collection $ 3,803,773 

Total $ 16,455,907 

A.15 Reasons for Program Changes

The apparent decrease in respondent burden for this collection is due to the fact that the last OMB 

approval was for the main study high school transcript collection and 2013 update, while this request is 

for the second follow-up field test and only panel maintenance activities for the main study.
A. Justification Supporting Statement Request for OMB Review (SF83I)

26

A.16 Publication Plans and Project Schedule

The formal contract for HSLS:09 requires the following reports, publications, or other public 

information releases:

 Descriptive summaries of significant findings for dissemination to a broad audience;

 Detailed data file documentation describing all aspects of the main study design and data 

collection procedures, including an appendix summarizing the methodological findings from the 

field test;

 Complete data files and documentation for research data users in the form of both restricted-use 

and a public-use data files;

 Special tabulations of issues of interest to the higher education community, as determined by 

NCES.

The operational schedule for the HSLS:09 Second Follow-up field test is shown in Exhibit A-5.

Exhibit A-5. Operational Schedule for HSLS:09 Second Follow-up Field Test

HSLS:09 activity Start date End date

Field Test (FT) Data Collection 7/1/2014 8/28/2015

FT Instrument Development and System Support 7/1/2014 3/6/2015

FT Cognitive Interviews 11/26/2014 3/6/2015

FT Web/CATI Training 12/8/2014 4/9/2015

Conduct FT Tracing 1/12/2015 7/30/2015

FT Data Files 4/13/2015 8/28/2015

FT Reporting 5/26/2015 3/7/2016

Responsive Design Experiment tbd 8/31/2015

Second Follow-up Main Study (MS) Data Collection 11/26/2014 11/30/2018

OMB review of MS package 09/15/2015 --

MS Instrument Development and System Support 3/9/2015 1/26/2016

OMB review of Cognitive Testing request 3/15/2015 --

MS Data Elements and Justifications 4/22/2015 10/15/2015

MS Cognitive Testing 5/15/2015 7/15/2015

Panel Maintenance 7/10/2015 12/31/2015

MS Sampling 7/30/2015 11/11/2015

Develop Training Materials 11/30/2015 6/13/2016

MS CATI Training 11/30/2015 9/23/2016

MS Locating/Tracing Plan 12/29/2015 2/1/2016

Deliver MS item wording list 1/19/2016 3/21/2016

MS Tracing 2/29/2016 10/27/2016

MS Web/CATI Data Collection 3/28/2016 12/31/2016

MS CAPI Training 5/10/2016 8/26/2016

MS CAPI Data Collection 6/20/2016 11/30/2016

Student Financial Aid Records Collection 10/26/2016 12/29/2017

Postsecondary Transcript Collection 10/26/2016 12/29/2017

MS Data Collection Products 11/30/2016 12/29/2017

Student Financial Aid Records Products 10/12/2017 11/30/2018
Supporting Statement Request for OMB Review (SF83I) A. Justification

27

Postsecondary Transcript Products 10/12/2017 11/30/2018

Additional Panel Maintenance 1/1/2018 6/30/2018

A.17 Reason(s) Display of OMB Expiration Date Is Inappropriate

The expiration date for OMB approval of the information collection will be displayed on data 

collection instruments and materials. No special exception to this requirement is requested.

A.18 Exceptions to Certification for Paperwork Reduction Act Statement

There are no exceptions to the certification statement identified in the Certification for Paperwork 

Reduction Act Submissions of OMB Form 83-I.