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EDICS Tracking Number: Supporting Statement A

SUPPORTING STATEMENT A

FOR PAPERWORK REDUCTION ACT SUBMISSION

Survey of Post-Graduate Outcomes for International Education Fellowship Recipients

U.S. Department of Education, Office of Postsecondary Education, 

International and Foreign Language Education (IFLE)

EDICS Tracking Number:

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify 

any legal or administrative requirements that necessitate the collection. Attach a hard 

copy of the appropriate section of each statute and regulation mandating or authorizing 

the collection of information, or you may provide a valid URL link or paste the 

applicable section. Please limit pasted text to no longer than 3 pages. Specify the review 

type of the collection (new, revision, extension, reinstatement with change, 

reinstatement without change). If revised, briefly specify the changes. If a rulemaking 

is involved, make note of the sections or changed sections, if applicable.

This new information collection is required to respond to a statutory mandate from Congress 

contained in Title VI of the Higher Education Opportunity Act (HEOA), P.L. 110-315, Section 

602, which states: “The Secretary shall assist grantees in developing a survey to administer to 

students who have completed programs under this title to determine postgraduate employment, 

education, or training. All grantees, where applicable, shall administer such survey once every

two years and report survey results to the Secretary.” The statute is attached in hard copy and is 

also available online at: http://www.gpo.gov/fdsys/pkg/PLAW-110publ315/pdf/PLAW110publ315.pdf (page 257-258).

While the law does not specify due dates, we propose the following reporting schedule for this 

longitudinal survey. Respondents will be surveyed every two years, for a total of eight years. 

The first cohort will be Fiscal Year (FY) 2010, which consists of Academic Year (AY) 

2010/2011 and summer 2011. The first survey will be conducted in fall 2012. The first two 

programs will be the Foreign Language and Area Studies (FLAS) (CFDA 84.015B) and the 

Institute for International Public Policy (IIPP) (CFDA 84.269A). The survey will be expanded to 

other Title VI grantees in subsequent years. 

The target population for this data collection is fellowship recipients from the FLAS and IIPP 

programs who have completed the degree program they were in when they were given their 

fellowship. 
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EDICS Tracking Number: Supporting Statement A

2. Indicate how, by whom, and for what purpose the information is to be used. Except for 

a new collection, indicate the actual use the agency has made of the information 

received from the current collection.

By Whom:

The International and Foreign Language Education (IFLE) office within the Office of 

Postsecondary Education (OPE) at the U.S. Department of Education will assist grantees by 

providing the survey questions, which they will then administer to the students who have 

graduated from the fellowship programs. The grantees will report the results of the survey back 

to IFLE.

How

The tool that will be used by grantees to administer the survey is Qualtrics. Qualtrics was chosen 

over Survey Monkey because of its functionality that will allow IFLE to create the survey and 

then “share” it with grantees. Grantees can then distribute the questionnaire to fellows on their 

own. Qualtrics allows them to add their own name and logo for their institution, and to manage 

responses on their own. Since the legislation authorizing this survey requires that grantees 

administer the survey, this technical solution fits our needs well. IFLE can ensure that the 

questions asked in the survey are standardized, thus reducing the potential for measurement error 

that would result if the grantees all used different tools managed in different ways.

Purpose

The purpose of this collection is to gather data on program outcomes to demonstrate 

effectiveness and impact. The data will be compared with other national surveys done by the 

National Science Foundation and the Census, including the Survey of Earned Doctorates, Survey

of Doctorate Recipients, National Survey of College Graduates, and the American Community

Survey. Our survey includes questions that are taken from those standard surveys so that we can 

do a comparison between our fellowship recipients and the general population, to better measure 

the effects of our grant programs. 

The results of the survey will be available to grantees and the public on our website at 

http://www2.ed.gov/about/offices/list/ope/iegps/index.html Congress and the Administration 

can use the results as a policy-making resource for international education. IFLE will be able to 

use the survey results to improve the Title VI and Fulbright-Hays programs. Grantees can use 

the results to improve their administration of the programs. 
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EDICS Tracking Number: Supporting Statement A

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms 

of information technology, e.g. permitting electronic submission of responses, and the 

basis for the decision of adopting this means of collection. Also describe any 

consideration given to using technology to reduce burden.

The survey will be conducted electronically. Grantees will use Qualtrics to send an email to 

respondents that will include a website link where they can complete the questionnaire.

We will conduct the survey electronically so that non-relevant questions can be skipped, thus 

reducing burden. The survey instrument included in this package contains notations about which 

questions are skipped based on the response to an individual question.

In addition to skip patterns, Qualtrics will allow us to pre-populate basic data from the initial 

survey to subsequent years. For example, questions about the FLAS profile and demographics 

will not change, so these questions can be skipped once they are answered in the original survey.

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 

2 above.

The information collection will not duplicate any other collections. Data on post-graduate 

outcomes of fellowship recipients is not currently being collected.

The only other information collected about these programs is their performance reports 

submitted through the International Resource Information System (IRIS, OMB No. 1840-0759 

Expiration Date 04/30/2013). However, IRIS collects data directly from grantees and only a 

minimal amount from fellows, and it does not include data on fellows after the end of the grant 

program. Post-graduate outcomes are not captured.

The statute authorizing this survey is clear that the Department itself is not supposed to 

administer the survey directly. The grantees must administer the survey and report the results to 

the Department. There are several challenges associated with this restriction. To properly 

collect data through a survey that will provide reliable results, we cannot let grantees ask 

questions of their fellows in different ways that may lead to measurement errors. The questions 

must be worded the same in order for the results to be reliable and for any conclusions to be 

drawn. If we provided the questionnaire to grantees and asked them to administer it and then 

report the results through IRIS, we would not have any way to ensure the reliability of the data. 

Qualtrics solves this problem. Qualtrics allows IFLE to create a questionnaire and “share” it 

with other users. Those users can then administer the survey and then submit the reports back to 

IFLE. They retain control of their own responses from their graduates, which they can analyze 

on their own, while the Department is able to ensure consistency and can analyze the results for 

the entire program.
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EDICS Tracking Number: Supporting Statement A

5. If the collection of information impacts small businesses or other small entities, describe 

any methods used to minimize burden. A small entity may be (1) a small business which 

is deemed to be one that is independently owned and operated and that is not dominant 

in its field of operation; (2) a small organization that is any not-for-profit enterprise 

that is independently owned and operated and is not dominant in its field; or (3) a small 

government jurisdiction, which is a government of a city, county, town, township, 

school district, or special district with a population of less than 50,000.

Small businesses or other small entities are not part of the target population of the information 

collection.

6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to 

reducing burden.

Title VI of the Higher Education Opportunity Act of 2008 requires this biennial data collection. 

The Secretary – and the grantees – would be out of compliance with the statute if the information 

were not collected.

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner:

 requiring respondents to report information to the agency more often than 

quarterly;

 requiring respondents to prepare a written response to a collection of 

information in fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any 

document;

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed 

and approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority 

established in statute or regulation, that is not supported by disclosure and data 

security policies that are consistent with the pledge, or that unnecessarily 

impedes sharing of data with other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures 

to protect the information’s confidentiality to the extent permitted by law.

There are no special circumstances that would require this information collection to be 

conducted in any of the ways listed as part of this question.

8. As applicable, state that the Department has published the 60 and 30 Federal Register 

notices as required by 5 CFR 1320.8(d), soliciting comments on the information 
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EDICS Tracking Number: Supporting Statement A

collection prior to submission to OMB. Summarize public comments received in 

response to that notice and describe actions taken by the agency in response to these 

comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record 

keeping, disclosure, or reporting format (if any), and on the data elements to be 

recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or 

those who must compile records should occur at least once every 3 years – even if the 

collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

A 60-day notice and a 30-day notice about this information collection was published in the 

Federal Register and allowed public comment. The Department summarized public comments 

and responded to them. Small changes were made to the original information collection based 

on feedback received in the public comments. IFLE also revised some survey terms (such as 

4d) to provide more clarity to respondents.

IFLE staff has consulted extensively with groups and individuals to refine the survey. In July

2011, IFLE hosted a webinar for all FLAS grantees. One of the main topics was plans for the 

survey and ways that we were soliciting feedback. We discussed the availability of data, the 

schedule for the survey, the technical issues with different web-based survey tools, and the 

research questions on which the survey would focus. During the webinar, we asked if there were 

any grantees that had existing post-graduate tracking surveys and results from those surveys that 

they would be willing to share with us. Based on these responses, we convened a focus group of 

9 individuals with experience surveying this population in September 2011. The focus group 

included representatives of institutions of higher education who have received FLAS and IIPP 

grants, as well as Department experts. Department experts included a statistician, multiple 

subject matter experts, and the Director of the Policy and Programs Studies Service within the 

Office of Planning, Evaluation, and Policy. The group reviewed research questions and draft 

surveys; discussed reporting definitions and procedures; and provided IFLE with feedback on the 

survey. 

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees with meaningful justification.

No payment or gift will be provided to respondents in connection with this data collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information 

(PII) is being collected, a Privacy Act statement should be included on the instrument. 

Please provide a citation for the Systems of Record Notice and the date a Privacy 

Impact Assessment was completed as indicated on the IC Data Form. A confidentiality 
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EDICS Tracking Number: Supporting Statement A

statement with a legal citation that authorizes the pledge of confidentiality should be 

provided. Requests for this information are in accordance with the following ED and 

OMB policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation 

– Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency 

Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, 

OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 –

Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable 

Information). If the collection is subject to the Privacy Act, the Privacy Act statement is 

deemed sufficient with respect to confidentiality. If there is no expectation of 

confidentiality, simply state that the Department makes no pledge about the 

confidentially of the data.

A Privacy Impact Assessment was submitted to the Department in March 2012. It was 

determined that the information being requested does not contain personally identifiable 

information. 

The Department does not make a pledge about the confidentiality of data. The introduction to 

the survey states: “This survey asks about your employment and education after the completion 

of the [insert program name] fellowship program. The purpose of the survey is to report to U.S. 

Department of Education on the impact of this taxpayer-funded program, which will help ensure 

that future students can also benefit from the fellowships. The survey is a legislative requirement 

of the Higher Education Opportunity Act of 2008. Your answers will be provided to the 

university that awarded your fellowship. They will report fellow responses to U.S. Department 

of Education. The survey should take approximately fifteen minutes to complete. Thank you for 

your time.”

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly 

considered private. The justification should include the reasons why the agency 

considers the questions necessary, the specific uses to be made of the information, the 

explanation to be given to persons from whom the information is requested, and any 

steps to be taken to obtain their consent.

The information collection includes no questions of a sensitive nature. The respondents should 

feel comfortable answering any of the questions.

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

should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the 

burden was estimated, including identification of burden type: recordkeeping, 

reporting or third party disclosure. All narrative should be included in item 12. 

Unless directed to do so, agencies should not conduct special surveys to obtain 
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EDICS Tracking Number: Supporting Statement A

information on which to base hour burden estimates. Consultation with a 

sample (fewer than 10) of potential respondents is desirable. If the hour burden 

on respondents is expected to vary widely because of differences in activity, size, 

or complexity, show the range of estimated hour burden, and explain the reasons 

for the variance. Generally, estimates should not include burden hours for 

customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour 

burden estimates for each form and aggregate the hour burdens in the ROCIS 

IC Burden Analysis Table. (The table should at minimum include Respondent 

types, IC activity, Respondent and Responses, Hours/Response, and Total 

Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate 

categories. The cost of contracting out or paying outside parties for information 

collection activities should not be included here. Instead, this cost should be 

included in Item 14.

Number of Fellowship recipient 

respondents (estimated)

4,468 individuals

Frequency of response

Survey will be administered 

every 2 years starting in Fall 

2012

1,569 will be surveyed twice 

(cohorts 1 and 2)

2,899 will be surveyed once 

(cohorts 3 and 4)

Annual hour burden

15 minutes per respondent

670 hours total

How was this burden estimated? Pilot testing of under 10 

respondents

Annual cost to fellow 

respondents

No cost

Number of Fellowship 

Coordinators administering the 

survey (estimated)

127 individuals

Frequency Once every 2 years

Annual hour burden

1 hour per respondent

127 hours total

How was this burden estimated Number of Fellowship 

Coordinators

Annual cost to Fellow 

Coordinator respondents

$35 per hour

$4,445 per year
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EDICS Tracking Number: Supporting Statement A

Justification for Estimates

The target population for this data collection is fellowship recipients from the FLAS and IIPP 

programs who have completed the degree program they were in when they were given their 

fellowship. So we are not surveying all fellows; just the ones who have graduated, since we are 

interested in employment outcomes. FLAS and IIPP Fellowship Coordinators are responsible 

for administering the suvrey to their respective fellows. This entails tracking their fellows, 

inputting fellow e-mail contact information into Qualtrics, and administering the survey. 

Coordinators will be responsible for following up on non-respondents. 

Each year there are approximately 2,100 FLAS fellows and 20 IIPP fellows. However, not all of 

the FLAS fellows will have graduated. For FY10, only 18% of FLAS fellows graduated, 

according to their performance reports submitted to ED. 

We also know that over the past five years, the distribution of FLAS fellows has been that 42% 

are doctoral students, 40% are Masters degree-only students, 13% are Masters/doctoral students, 

and 5% are undergraduates. Based on this distribution, we have made the following estimates 

about fellows and when they will graduate.

We estimate that 20% of a cohort of fellows will graduate in the same year in which they

received their degree. Another 30% of those will graduate the following year, since many of the 

recipients are Masters degree students in two year programs. In the third year, an estimated 25% 

will graduate, and in the fourth, 15% will graduate, for a total of 90% graduating within four 

years. The remaining 10% are students who remain in school, which includes doctoral students 

who take longer than four years to complete their program.

 

See estimates and calculations below. The total of 2,217 for cohort 1 is based on actual data 

about fellows. Chorts 2, 3, and 4 are estimates.

FLAS Estimations for Graduation by Fellow Cohort and by Year, FY10 – FY13

% 

Graduating

# 

Graduating

% 

Graduating

# 

Graduating

% 

Graduating

# 

Graduating

% 

Graduating

# 

Graduating

Cohort 1 - Fellowship 

received in FY2010

2,217 20% 443 30% 665 25% 554 15% 100 1,763

Cohort 2 - Fellowship 

received in FY2011

2,100 N/A N/A 20% 420 30% 630 25% 105 1,155

Cohort 3 - Fellowship 

received in FY2012

2,100 N/A N/A N/A N/A 20% 420 30% 630 1050

Cohort 4 - Fellowship 

received in FY2013

2,100 N/A N/A N/A N/A N/A N/A 20% 420 420

Total by Year 443 1,085 1,604 1,255 4,388

Total by 

Cohort FLAS Fellow Cohorts Totalfellows

Graduate in FY10 Graduate in FY11 Graduate in FY12 Graduate in FY13
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EDICS Tracking Number: Supporting Statement A

Each year, the IIPP program graduates approximately 20 students. Adding together the FLAS 

estimates above and the IIPP graduates, we estimate that 1,569 fellows could potentially be 

surveyed in FY12. For the next survey two years later, in FY14, the estimate is 4,468. The 

number is higher for the second survey because we will have more cohorts and we expect more 

FLAS fellows to have graduated by then. The 1,569 individuals surveyed in FY12 will be

surveyed a second time in FY14. So the total unique individuals surveyed will be 4,468.

Burden Estimations for FLAS and IIPP Cohorts, by Graduation Year and Survey Year

FLAS Cohort 1, graduated in FY10 and 

FY11

1,109

FLAS Cohort 2, graduated in FY11 420

IIPP Cohort 1, graduated in FY10 20

IIPP Cohort 2, graduated in FY11 20

Total 1,569

FLAS Cohort 1, graduated FY10 - FY13 1,763

FLAS Cohort 2, graduated FY11 - FY13 1,155

FLAS Cohort 3, graduated FY 12 and FY13 1,050

FLAS Cohort 4, graduated FY13 420

IIPP Cohort 1, graduated in FY10 20

IIPP Cohort 2, graduated in FY11 20

IIPP Cohort 1, graduated in FY12 20

IIPP Cohort 2, graduated in FY13 20

Total 4,468

Potential

Survey 

Respondants 

for FY12 Survey

Potential

Survey 

Respondantsfor

FY14 Survey

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour 

burden shown in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and 

start-up cost component (annualized over its expected useful life); and (b) a total 

operation and maintenance and purchase of services component. The estimates 

should take into account costs associated with generating, maintaining, and 

disclosing or providing the information. Include descriptions of methods used to 

estimate major cost factors including system and technology acquisition, 

expected useful life of capital equipment, the discount rate(s), and the time 

period over which costs will be incurred. Capital and start-up costs include, 

among other items, preparations for collecting information such as purchasing 

computers and software; monitoring, sampling, drilling and testing equipment; 

and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of 

cost burdens and explain the reasons for the variance. The cost of contracting 

out information collection services should be a part of this cost burden estimate. 

In developing cost burden estimates, agencies may consult with a sample of 

respondents (fewer than 10), utilize the 60-day pre-OMB submission public 
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EDICS Tracking Number: Supporting Statement A

comment process and use existing economic or regulatory impact analysis 

associated with the rulemaking containing the information collection, as 

appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory 

compliance with requirements not associated with the information collection, (3) 

for reasons other than to provide information or keep records for the 

government or (4) as part of customary and usual business or private practices.

Also, these estimates should not include the hourly costs (i.e., the monetization of 

the hours) captured above in Item 12

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

There is no capital, start-up, or maintenance cost to respondents. Record keepers are already

maintaining graduation dates and email addresses for their fellows.

14. Provide estimates of annualized cost to the Federal government. Also, provide a 

description of the method used to estimate cost, which should include quantification of 

hours, operational expenses (such as equipment, overhead, printing, and support staff), 

and any other expense that would not have been incurred without this collection of 

information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a 

single table.

The annualized cost to the Federal government will be approximately $171,550. This cost 

includes the equivalent of 6 months of senior federal government staff time and the cost of 

employing a contractor to clean the data, analyze the data, and assist with preparing a draft of the 

final report. It also includes the cost of approximately $6,250 a year for three years, for the 

Qualtrics software.

Hours Salary Total

Qualtrics Software $6,250 (per year/3 

years)

$18,750

Contractor Fixed price Contract $100,000

Senior Program 

Officer

960 (6 months) $55/hr $52,800

15. Explain the reasons for any program changes or adjustments. Generally, adjustments 

in burden result from re-estimating burden and/or from economic phenomenon outside 

of an agency’s control (e.g., correcting a burden estimate or an organic increase in the 

size of the reporting universe). Program changes result from a deliberate action that 

materially changes a collection of information and generally are result of new statute or 

an agency action (e.g., changing a form, revising regulations, redefining the respondent 
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EDICS Tracking Number: Supporting Statement A

universe, etc.). Burden changes should be disaggregated by type of change (i.e., 

adjustment, program change due to new statute, and/or program change due to agency 

discretion), type of collection (new, revision, extension, reinstatement with change, 

reinstatement without change) and include totals for changes in burden hours, 

responses and costs (if applicable).

This is a new information clearance package mandated by the Higher Education Opportunity Act 

(HEOA) of 2008. Section 601 requires that; “The Secretary shall assist grantees in developing a 

survey to administer to students who have completed programs under this title to determine 

postgraduate employment, education, or training. All grantees, where applicable, shall 

administer such survey once every two years and report survey results to the Secretary.” The 

burden hour for this collection is 797.

16. For collections of information whose results will be published, outline plans for 

tabulation and publication. Address any complex analytical techniques that will be 

used. Provide the time schedule for the entire project, including beginning and ending 

dates of the collection of information, completion of report, publication dates, and other 

actions.

The first survey will be conducted in fall 2012 for a period of two months. IFLE and a 

contractor will then analyze the data. A draft report will be submitted internally to the 

Department three months later. After internal approval, estimated to take two months, it will be 

published online for grantees and the public on our website at 

http://www2.ed.gov/about/offices/list/ope/iegps/index.html. 

This timeline is dependent upon approval for this information collection package. Below is the 

tentative schedule.

Survey Collection, Processing, Publication

8/2012 Training of grantees 

9/2012 Start of survey

11/2012 Close of survey

4/2013 Data analysis complete

7/2013 ED approval of report complete

8/2013 Release of report to the public

The analytical techniques that will be used will include frequency distributions and descriptive 

statistics. The responses to questions from other national surveys done by the National Science 

Foundation and the Census, including the Survey of Earned Doctorates, Survey of Doctorate 

Recipients, National Survey of College Graduates, and the American Community Survey will be 

compared to the national population. 
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EDICS Tracking Number: Supporting Statement A

17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

IFLE will instruct grantees to display the expiration date for OMB approval of the information 

collection on the questionnaire.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

There are no exceptions to the statement.