1

SUPPORTING	STATEMENT	A:

REQUEST	FOR	CLEARANCE	OF	INFORMATION	

COLLECTION	FORMS	FOR

“An	Examination	of	Trends	in	

Algebra	II	Enrollment	and	

Completion	in	Texas	Public	High	

Schools ”

December 2014

Submitted to: Submitted by:

U.S. Department of Education SEDL

Institute of Education Sciences 4700 Mueller Blvd.

555 New Jersey Ave. NW, Rm. 308 Austin, TX 78723

Washington, DC 20208 Phone: (800) 476-6861

4700 Mueller Blvd. Austin, TX 78723

800-476-6861

www.relsouthwest.org

This publication was prepared for the Institute of Education Sciences (IES) under contract ED-IES-12-C-00012 by 

Regional Educational Laboratory Southwest, administered by SEDL. The content of the publication does not 

necessarily reflect the views or policies of IES or the U.S. Department of Education, nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. government. The publication is in the public 

domain. Authorization to reproduce in whole or in part for educational purposes is granted.
2

Contents

Introduction ..................................................................................................................................................3

A. Justification...............................................................................................................................................7

1. Circumstances Necessitating the Data Collection................................................................................7

2. How, by Whom, and for What Purpose Information Is to Be Used....................................................10

3. Use of Automated, Electronic, Mechanical, or Other Technological Collection Techniques.............12

4. Efforts to Avoid Duplication of Effort..................................................................................................12

5. Sensitivity to Burden on Small Entities...............................................................................................13

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is 

Conducted Less Frequently Than Proposed............................................................................................13

7. Special Circumstances.........................................................................................................................13

8. Federal Register Announcement and Consultation............................................................................13

c. Unresolved Issues............................................................................................................................15

9. Payment or Gift to Respondents.........................................................................................................15

10. Data Confidentiality ..........................................................................................................................15

11. Additional Justification for Sensitive Questions ...............................................................................17

12. Estimates of Hour Burden.................................................................................................................17

13. Estimate of Total Annual Cost Burden to Respondents or Record-Keepers.....................................20

14. Estimates of Annualized Cost to the Federal Government...............................................................20

15. Reasons for Program Changes or Adjustments ................................................................................20

16. Plan for Tabulation and Publication and Schedule for Project.........................................................20

17. Approval Not to Display the Expiration Date for OMB Approval......................................................22

18. Exception to the Certification Statement .........................................................................................23

References ..................................................................................................................................................24

Attachment A-1. District Staff Survey .........................................................................................................25

Attachment A-2. Follow-up Email...............................................................................................................26

Attachment A-3. Follow-up Telephone Script ............................................................................................27

Attachment A-4. Student Records Data......................................................................................................28

Attachment A-5. IRB Approval....................................................................................................................29

Attachment A-6. Educational Sciences Reform Act (ESRA) ........................................................................30

Attachment A-7. Federal Register Notices..................................................................................................31

Attachment A-8. Confidentiality Form and Affidavits.................................................................................32

Attachment A-9. Technical Working Group Suggestions............................................................................33
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Introduction

The U.S. Department of Education (ED) requests clearance for data collection under the Office 

of Management and Budget (OMB) clearance agreement (OMB number 1850-NEW) for 

activities related to the Regional Educational Laboratory (REL) Program. ED, in consultation with 

SEDL, intends to study changes in student mathematics course-taking and course failures, as 

well as changes in district mathematics course offerings and diploma plan placement, that 

occur after implementation of Texas House Bill 5 (HB 5)—the Foundation High School Program.

This is a descriptive study. 

Under the Foundation High School Program, students may select from among three different 

graduation plans—the Foundation Plan, the Foundation plus Endorsement Plan, and the 

Distinguished Plan. Prior to implementation of the Foundation High School Program, which 

commenced with the incoming cohort of grade 9 students in the 2014-15 school year, students 

were required to complete algebra II in order to graduate from a Texas public high school1. 

Under the Foundation High School Program, students may elect to complete algebra II2, but 

they are no longer required to do so in order to graduate. Currently, the public universities in 

Texas require students to have completed algebra I, geometry, and algebra II in order to gain 

admission. Despite the disparity between some of the new graduation plans and admission 

requirements to state four-year colleges, the Texas Higher Education Coordinating Board has 

stated that the universities will not be changing their admissions requirements. Removing the 

algebra II graduation requirement for all high school students will affect some students’ 

eligibility for admission to state four-year colleges and universities.

In addition, the State Board of Education has opted to change the Texas 10 percent rule, which 

offers admission to state-funded universities to all Texas high school students who graduate in 

the top 10 percent of their class, to only include students who graduate in the top ten percent 

of their class and complete the foundation plus distinguished plan beginning with the 2014–15 

incoming cohort of grade 9 students. Thus, opting not to complete algebra II could have 

important consequences for Texas high school graduates.

OMB approval is being requested for a survey data collection in Texas public school districts to 

discern what districts in Texas are doing in response to HB 5 with regard to diploma plan 

placement, advanced mathematics course offerings, and information dissemination about the 

new graduation requirements.

 

1

Prior to HB 5, students were only allowed to complete the minimum high school graduation requirements, which 

did not include algebra II, if they received special permission.

2

Algebra II is required for students who wish to complete the STEM endorsement or the Distinguished Plan.
4

The Texas Education Agency (TEA) wishes to understand any changes in algebra II enrollment, 

algebra II completion, and third mathematics course3failure rates that occur after enactment of 

HB 5. In particular, this study will inform TEA about the mathematics courses students are 

completing by the end of their junior year4, as well as whether or not fewer students, 

particularly low-income and minority students, are enrolling in algebra II, completing algebra II, 

and/or failing their third mathematics course by the end of junior year. TEA will be able to use 

this information to answer questions about changes in course taking patterns and course failure 

rates that may arise from parents, education practitioners and administrators, policymakers, 

and researchers. It will also allow them to respond to inquiries regarding any variation in how 

districts responded to the HB 5 graduation requirements. For example, the Associate 

Commissioner for Standards and Programs, who is in charge of curriculum and instruction for 

TEA is interested in learning which mathematics courses student are completing. In particular 

the Commissioner is interested knowing the number of new math courses districts are creating 

and/or adding in order for students to be able to complete the endorsements. Similarly, district 

administrators are curious to know what other districts are doing with regard to changes in the 

courses offered in the districts in order to allow students to complete the new endorsements, 

particularly in mathematics. 

This study also will provide TEA and the Texas Higher Education Coordination Board (THECB)

with information on the level of Texas students’ college preparation in mathematics. This 

information should be of particular interest to THECB. In the 2013 State of Higher Education 

Address, Commissioner Raymond Paredes reported that while overall higher education 

enrollments are on track to meet 2015 goals, Fall 2013 preliminary data show that enrollment 

rates have slowed, especially among Black and Hispanic males. HB 5 has the potential to reduce 

enrollment rates even more, especially for low-income and minority students who are already 

less likely to take a rigorous high school curriculum. This study will provide TEA and THECB with 

information about changes in students’ college readiness (as defined by mathematics course 

completion) that it can report to the Texas state legislature.

This study will address the following research questions: 

1) What is the trend in student enrollment in algebra II by the end of grade 11 for 

students who entered grade 9 during the 2004-05 through 2014-15 academic years?

a. Does the trend in student enrollment in algebra II by the end of grade 11 across 

these cohorts differ by:

i. Gender?

 

3

Students in Texas must complete algebra I and geometry in order to graduate from a public high school. After 

students have completed algebra I and geometry, they must select a third advanced mathematics course from an 

approved list of courses, which includes algebra II.

4

Due to time constraints inherent in the REL contract, we will be able to follow students only through grade 11. 

However, course-taking patterns suggest that if students have not completed Algebra II by the end of their junior 

year, it is unlikely they will do so in their senior year.
5

ii. Race/ethnicity?

iii. Free or reduced price lunch eligibility?

iv. Student achievement?

b. Does the trend in student enrollment in algebra II by the end of grade 11 across 

these cohorts differ between:

i. High-minority and low-minority districts5?

ii. High-income and low-income districts6?

iii. Geographic locations (i.e., urban, rural, suburban)?

iv. Regions of Texas (i.e., north, south, east, west, and central)?

2) What is the trend in student completion of algebra II by the end of grade 11 for 

students who entered grade 9 during the 2004-05 through 2014- academic years?

a. Does the trend in student completion of algebra II by the end of grade 11 across 

these cohorts differ by:

i. Gender?

ii. Race/ethnicity?

iii. Free or reduced price lunch eligibility?

iv. Student achievement?

b. Does the trend in student completion of algebra II by the end of grade 11 across 

these cohorts differ between:

i. High-minority and low-minority districts?

ii. High-income and low-income districts?

iii. Geographic locations (i.e., urban, rural, suburban)?

iv. Regions of Texas (i.e., north, south, east, west, and central)?

3) What is the trend in third mathematics course failure by the end of grade 11 for 

students who entered grade 9 during the 2004-05 through 2014-15 academic years? 

a. Does the trend in third mathematics course failure by the end of grade 11 across 

these cohorts differ by:

i. Gender?

ii. Race/ethnicity?

iii. Free or reduced price lunch eligibility?

iv. Student achievement?

b. Does the trend in third mathematics course failure by the end of grade 11 across 

these cohorts differ between:

i. High-minority and low-minority districts?

ii. High-income and low-income districts?

iii. Geographic locations (i.e., urban, rural, suburban)?

 

5

High-minority districts are districts with percentages of minority students (i.e., American Indian or Alaska Native, 

Black, Hispanic, Native Hawaiian or Other Pacific Islander, Two or more races) that are in the top one-third of all 

districts in the state. Low-minority districts are districts with percentages of minority students that are in the 

bottom one-third of all districts in state. 

6

High-income districts are districts with percentages of students who are eligible for free/reduced price lunch that 

are in the top one-third of all districts in the state. Low-income districts are districts with percentages of students 

who are eligible for free/reduced price lunch that in the bottom one-third of all districts in the state. 
6

iv. Regions of Texas (i.e., north, south, east, west, and central)?

4) How are districts enacting the graduation requirement provisions of HB 5?

5) Which advanced mathematics courses are districts offering students who enter 

grade 9 after the enactment of House Bill 5?

6) Which mathematics courses do students who enter grade 9 after the enactment of 

House Bill 5 complete by the end of their junior year? 

a. Do the mathematics courses that students complete differ by:

i. Gender?

ii. Race/ethnicity?

iii. Free or reduced price lunch status?

iv. Student achievement?

v. The diploma plan into which districts automatically place their students7?

7) Are there differences in the mathematics courses that students complete by the end 

of their junior year before (2014-15 through 2015-16) and after enactment of House 

Bill 5 (2016-17)?

a. Do the mathematics courses that students complete differ by:

i. The diploma plan into which districts automatically place their students?

Data collection for this project consists of online surveys to be administered to district 

administration staff who work in Texas public school districts. Specifically, in this OMB 

clearance package, ED is requesting clearance for the following data collection approach:

 A web-based survey of district administrative staff in Texas public high school districts, 

including follow-up telephone calls

 Extant data collection consisting of student records data to be obtained from the Texas 

Education Agency

 A review of information on school district websites for each of Texas’ school districts

ED believes that the data collections for which clearance is being requested represent the bare

minimum necessary to describe trends in algebra II enrollment, algebra II completion, and third 

mathematics course failures; district responses to changes in the Texas high school graduation 

plans; and student mathematics course-taking patterns before and after the enactment of HB 5. 

 

7

Several district in Texas have indicated that they will begin placing all incoming grade 9 students in the 

distinguished diploma plan. Students will have the opportunity to opt into a different diploma plan after their 

sophomore year.
7

A. Justification

1. Circumstances Necessitating the Data Collection

In June 2013, Texas Governor Rick Perry signed House Bill (HB) 5—the Foundation High School 

Program—into law, which changed high school graduation requirements and reduced the 

number of required state secondary school exams in the state. HB 5 also grants the Texas State 

Board of Education (SBOE) decision-making authority on a number of other graduation-related 

issues. Prior to HB 5, Texas students could choose between two graduation plans: 

recommended and distinguished, with special provisions given for students to drop down to a 

minimum plan.

8

In both the recommended and distinguished plans, students were required to 

take four courses each in English, mathematics, science, and social studies—earning the credits 

they needed to be admitted to most state universities and colleges.

With the enactment of HB 5, these two high school graduation plans were replaced with three 

new graduation plans: foundation, foundation plus endorsement,

9

and foundation plus 

distinguished. The foundation plan was crafted to give students who want to go directly into 

career and technical fields the flexibility to take more classes focused on their interests, instead 

of college preparation classes. Under the foundation plan, the number of credits required to 

graduate has been reduced from 26 to 22, and students are required to complete only three 

courses each in science, social studies, and mathematics. The foundation plus endorsement 

plan requires students to continue to earn 26 credits to graduate. Students selecting this plan 

must continue to complete four courses each in English, mathematics, and science; however, 

the third and fourth mathematics courses do not have to include algebra II, with the exception 

of the STEM endorsement10. Only students completing the foundation plus distinguished plan 

and the foundation plus STEM endorsement plan will continue to be required to complete four 

courses each in English, science, and mathematics, including algebra II—the course 

requirements for admission to most state four-year colleges and universities. 

In response, the SBOE has opted to change the Texas 10 percent rule, which offers admission to 

state-funded universities to all Texas high school students who graduate in the top 10 percent 

 

2

Only students meeting strict criteria were able to select the minimum plan, and a waiver acknowledging 

understanding of the Texas Minimum Graduation Plan had to be signed by a student’s parent or guardian.

9

The endorsements include science, technology, engineering, and mathematics (STEM); business and industry; 

public services; arts and humanities; and multidisciplinary studies.

10 A student may earn a STEM endorsement by completing foundation and general endorsement requirements 

including Algebra II, chemistry, physics, a coherent sequence of four or more credits in Career and Technical 

Education (CTE) that consist of at least two courses in the same career cluster including at least one advanced CTE 

course which includes any course that is the third or high course in a sequence, and a coherent sequence of four 

credits in computer science selected from the approved list. 
8

of their class, to only include students who graduate in the top ten percent of their class and 

complete the foundation plus distinguished plan beginning with the 2014–15 incoming cohort 

of grade 9 students. 

The public universities in Texas still require students to have completed algebra I, geometry, 

and algebra II in order to gain admission, despite the disparity between some of the new 

graduation plans and admission requirements to state four-year colleges. As such, removing the 

algebra II graduation requirement for all high school students will affect some students’ 

eligibility for admission to state four-year colleges and universities. 

To investigate trends in algebra II enrollment, algebra II completion, and third mathematics 

course failure, we will plot the algebra II enrollment, algebra II completion, and third 

mathematics course failure rates by the end of grade 11 over time for all public high schools in 

Texas for the incoming cohorts of students. Particular attention will be paid to trends in the 

algebra II enrollment, algebra II completion, and third mathematics course failure rates of lowincome, low-achieving, and minority students. We will also describe how districts are 

responding to HB 5. Specifically, we will describe whether districts are opting to automatically 

place students into a specific diploma plan, and if so , which plan; changes in the number and 

type of mathematics courses offered; and how districts are communicating with parents about 

changes to the high school graduation requirements being implemented under HB 5. This study 

will utilize extant student- and school-level data collected and archived by TEA, data retrieved 

from district websites, and a survey administered to district administrators. Table 1 lists the 

data source used to address each of the research questions. 

Table 1. Data sources used to address each research question

Research Question

TEA Survey

1. What is the trend in student enrollment in algebra II by 

the end of grade 11 for students who entered grade 9 

during the 2004-05 through 2014-15 academic years?

X

2. What is the trend in student completion of algebra II by 

the end of grade 11 for students who entered grade 9 

during the 2004-05 through 2014-15 academic years?

X

3. What is the trend in third mathematics course failure by 

the end of grade 11 for students who entered grade 9 

during the across the 2004-05 through 2014-15 academic 

years? 

X
9

4. How are districts enacting the graduation requirement 

provisions of HB 5? X

5. Which advanced mathematics courses are districts 

offering students who enter grade 9 after the enactment of 

House Bill 5?

X

6 Which mathematics courses do students who enter grade 

9 after the enactment of House Bill 5 complete by the end of 

their junior year? 

X

7. Are there differences in the mathematics courses that 

students complete by the end of their junior year before

(2014-15 through 2015-16) and after enactment of House 

Bill 5 (2016-17)?

X

To answer research questions 1, 2, 3, 6, and 7, REL Southwest will utilize student- and schoollevel data sets available from the TEA. Specifically, the study will use data from TEA’s Public 

Education Information Management System (PEIMS), statewide assessment files, and Texas 

Academic Performance Report (TAPR) files. PEIMS contains data on student enrollment and 

demographic characteristics, special program participation, and course completion data, while 

the statewide assessment files contain data on students’ performance on the STAAR 

assessments. TAPR contains organizational data for schools and districts. 

To answer research questions 4 and 5, we will use an online survey, as well as information 

posted on district websites collected as part of a separate study to describe how districts are 

responding to the provisions of HB 5. Specifically, we will use data collected by a separate fast 

response study to describe which graduation plan, if any, districts are automatically placing 

students in upon enrollment in grade 9. We will use the online survey to fill in the gaps from the 

website search regarding which graduation plan, if any, districts are automatically placing 

students and to determine the number and type of endorsements districts are offering. REL 

Southwest will administer the online survey to district staff who oversee curriculum and 

instruction. See attachment A-1 for a copy of the survey.

The timeline for data collection is shown in Table 2. 
10

Table 2. Data Collection Timeline

Data Collection Purpose

Requesting 

OMB 

Clearance?

Oct /Nov

2015 July 2017

Extant district staff 

contact information

 Email addresses and telephone 

numbers for dissemination of 

online surveys Yes X

District staff surveys  Student diploma plan placement

 Endorsements offered

 Advanced mathematics courses 

offered

 Parent information dissemination

Yes X

Extant administrative 

school and student 

data from the Texas 

Education Agency

 Student mathematics course 

enrollment, completion, and failure 

data

 Student background characteristics

 Description of Texas public high 

schools

Yes X

2. How, by Whom, and for What Purpose Information Is to Be Used

ED’s contractor for REL Southwest will analyze the data to be collected through this study using 

statistical models and procedures that are preapproved by the Institute of Education Sciences 

(IES). The contractor will then summarize the findings in a report that will undergo review for 

quality and relevance by the National Center for Education Evaluation and Regional Assistance’s 

(NCEE’s) external review contractor. After the report has undergone IES review, findings will be 

presented to TEA (the primary audience) and published through IES for educators and 

education researchers (secondary audience).

To provide this information to the primary audience and the secondary audience, ED’s 

contractor is requesting OMB clearance to collect the three types of data listed in Table 2. The 

contractor is requesting OMB clearance to collect two types of extant data from TEA:

1) TEA administrative student data. For this project, REL Southwest will use TEA’s 

Public Education Information Management System (PEIMS), statewide assessment 
11

files and Texas Academic Performance Report (TAPR) files data files (research 

questions 1, 2, 3, 6 and 7). Since we are requesting data for all students in all public 

schools in the state as opposed to requesting a customized report, we do not 

anticipate that it will place much of a time burden on TEA staff to provide us with 

this data—not more than 2-3 hours. 

2) District staff email addresses and phone numbers from TEA. REL Southwest will 

obtain a list of district superintendent email addresses and telephone numbers in 

order to facilitate dissemination of the online surveys. The data is available from the 

TEA website site, and there is no associated time burden for TEA staff. 

ED’s contractor is also requesting OMB clearance to collect data via a district survey to be 

administered to all public school districts in the state of Texas:

3) District staff survey. In the fall of 2015, SEDL will send an email message to 

superintendents at each of the 1,026 public school districts in Texas containing a link 

to the online survey.11 The email message will inform respondents about the 

purpose of the survey and the intended use for the data. The survey will ask 

respondents to provide information on new mathematics courses offered in the 

district in response to HB 5, which endorsements are being offered at each of the 

schools in the district12, and the types of information being distributed to students 

and parents (and means of distribution) regarding changes to the high school 

graduation requirements enacted under HB 5. The survey will also ask districts to 

report which graduation plan, if any, they are automatically placing students in upon 

enrollment in grade 9. The survey will be sent to district superintendents; however, 

superintendents will be directed to forward the email to other district staff who 

might better be able to respond to the survey questions. After one week, a second 

electronic mail message will be sent to all nonrespondents. If a response to the 

survey is not received within one week of sending the second electronic mail 

message, telephone calls will be made to the district to collect this information.

 

11 We will obtain contact information from TEA’s website. ED’s contractors will include the link to the online survey 

in the email message explaining the intent and purpose of the survey, as this is more expedient than sending an 

initial email explaining the survey and inviting administrators to participate in it. That is, district administrators will 

have access to the survey immediately, rather than having to be on the lookout for an additional email. District 

administrators will have the opportunity to forward the email to other district staff, if desired. If district 

administrators do not complete the online survey, they will receive a phone call. At this time, another district staff 

member can be identified to provide the information.

12 There are approximately 1,026 school districts in Texas and most have a maximum of 2-3 high schools. 
12

Districts contacted via telephone will be asked to respond to the survey questions 

orally. A researcher will record their responses in the online survey form. 

The surveys are designed to be completed online in approximately 10-15 minutes. 

Since some districts will need to be contacted more than once, and some districts 

will complete the survey via telephone, it is assumed that the average burden per 

online survey response will be 15 minutes and the average burden per telephone 

survey response will be 20 minutes. For the purposes of this OMB package, it is 

assumed that district staff members for each of Texas’ 1,026 districts that include a 

high school will complete a district staff survey.

3. Use of Automated, Electronic, Mechanical, or Other Technological Collection 

Techniques

The data collection plan reflects sensitivity to issues of efficiency, accuracy, and respondent 

burden. To address the study’s research questions, the contractor will collect data using 

electronic data collection tools. The electronic tools include the following: 

 A secure electronic file transfer protocol site that allows TEA to transfer administrative 

records to ED’s contractor in an efficient and secure way.

 Online data collection tools (e.g., Survey Gizmo) that allows for the secure collection of 

survey responses and eliminates the need for third-party data entry

4. Efforts to Avoid Duplication of Effort

To the extent possible, this project will rely on extant administrative data or existing documents 

that are available for students, schools, and district staff, rather than asking individuals to 

provide the data for study purposes. The only data to be collected that will be unique to this 

study will be obtained via the district staff survey. Presently, no other systematic effort has 

been made or is currently underway to collect information regarding how districts are 

responding to the new graduation requirements implemented under HB 5; as such there is no 

alternative source of the information collected by the online district staff survey13.

 

13 A review of Texas public school district websites revealed that only about 45 percent of districts had some 

information about how they are responding to HB 5 available on the district website.
13

5. Sensitivity to Burden on Small Entities

The use of state-level administrative records will reduce the burden on districts by ensuring 

that only the minimum amount of original data is requested from districts in order to meet the 

objectives of this study. Aside from surveys emailed directly to district superintendents, ED’s 

contractors will not contact districts to request additional data.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not 

Conducted or Is Conducted Less Frequently Than Proposed

The Education Science Reform Act of 2002 states that the central mission and primary function 

of the regional education laboratories is to support applied research and provide technical 

assistance to state and local education agencies within their region (ESRA, Part D, section 

174[f]). If the proposed data were not collected, REL Southwest would not be fulfilling its 

central mission to serve the states in the region and provide support for evidence-based 

research. The research questions addressed in this study respond to questions raised by TEA, 

which is a constituent member of the REL Southwest. If the proposed data were not collected, 

TEA would not know how Texas public school students and districts are responding to the new 

graduation requirements outlined in HB 5. Because Texas is a leader among states as it relates 

to high school graduation standards (they were one of the first states to adopt a requirement 

that students complete Algebra II to graduate), the results of this study may also inform 

decisions regarding high school graduation requirements nationwide. 

7. Special Circumstances

This request for OMB clearance does not include any of the stipulated special circumstances 

and thereby fully complies with regulations.

8. Federal Register Announcement and Consultation

a. Federal Register Announcement

A 60-day Federal Register Notice was published on 1/02/2015. To date, no public 

comments have been received. A 30-day notice was issued at the same time the ICR was 

submitted to OMB for review.

b. Consultations Outside the Agency
14

ED and/or the REL Southwest contractor have consulted with individuals regarding the 

availability of data, the soundness of the evaluation design for addressing evaluation 

questions, and the clarity of measures. Specifically, a technical working group (TWG) 

comprising experts in research methodology and REL Southwest’s core areas of 

emphasis, which was assembled by the REL Southwest contractor to review studies. The 

TWG met twice, April 29, 2014 and August 4, 2014, to discuss the changes to the 

graduation requirements being implemented as a result of HB 5, the study 

methodology, and measures. The contractor was required to submit to ED the TWG 

comments and the contractors’ plan for addressing those comments (see appendix A-7).

Members of the TWG include:

Dan Goldhaber, Ph.D.

Director, CALDER (National Center for Analysis of Longitudinal Data in Education 

Research)

Vice President, American Institutes for Research (AIR) 

Director, Center for Education Data & Research (CEDR), University of Washington 

Bothell

Co-Editor, Education Finance and Policy

3876 Bridge Way N, Suite 201

Seattle, WA 98103

Ph: 206-547-1562

Fax: 206-547-1641

E-mail: dgoldhab@uw.edu

Geoffrey Borman, Ph.D.

Professor of Education, University of Wisconsin—Madison

Deputy Director of the University of Wisconsin's Predoctoral Interdisciplinary Research 

Training Program

Senior Researcher, Consortium for Policy Research in Education.

348 Education Building

1000 Bascom Mall

Madison, WI 53706-1326

Ph: 608-263-3688

Fax: 608-265-3135

E-mail: gborman@education.wisc.edu

Johannes M. (Hans) Bos, Ph.D.

Vice President and Program Director, International Development, Evaluation, and 

Research (IDER) Program
15

American Institutes for Research

2800 Campus Drive, Suite 200

San Mateo, CA 94403

Ph: 650-843-8100

Fax: 650-843-8200

E-mail: jbos@air.org

W. Steven Barnett, Ph.D.

Board of Governors Professor and Director of the National Institute for Early Education 

Research

Rutgers University

73 Easton Avenue

New Brunswick, NJ 08901

Ph: 848-932-4350 x23132

Fax: 732-932-4360

E-mail: sbarnett@nieer.org

c. Unresolved Issues

There are no unresolved issues.

9. Payment or Gift to Respondents

This request for OMB clearance does not include any payment or gifts to respondents. District 

staff will not be paid or provided monetary incentives for completing the online survey. Districts 

will be offered copies of the final aggregated, statewide results of the survey. District 

administrators are interested in what other districts are doing in response to the changes to the 

graduation requirements. 

10. Data Confidentiality

The data collection efforts that are the focus of this clearance package will be conducted in 

accordance with all relevant federal regulations and requirements. The Southwest REL will be 

following the new policies and procedures required by the Education Sciences Reform Act of 

2002, Title I, Part E, Section 183 requires “All collection, maintenance, use, and wide 

dissemination of data by the Institute” to “conform with the requirements of section 552 of 

title 5, United States Code, the confidentiality standards of subsection (c) of this section, and 
16

sections 444 and 445 of the General Education Provision Act (20 U.S.C. 1232g, 1232h).” These 

citations refer to the Privacy Act, the Family Educational Rights and Privacy Act, and the 

Protection of Pupil Rights Amendment.

Every measure will be taken to protect the confidentiality of the data collected and the data will 

be used for the purpose of the study. All survey responses will be kept strictly confidential, and 

will only be used for the purpose of the study. No one at the school, district, or the state will 

have access to survey responses that include respondents’ names, school names, or other 

information that could potentially be used to identify individuals or schools. The project has 

been approved by E&I Review Services, which serves as SEDL’s Institutional Review Board to 

review research involving human subjects. E&I is registered with the Office of Human Research 

Protection (OHRP). E&I’s IRB Organization number is 000065. E&I’s IRB Registration number, 

effective until November 28, 2015, is IRB00007807 (see attachment A-3).

In addition, for student information, the data collection efforts will ensure that all individually 

identifiable information about students, their academic achievements, their families and 

information with respect to individual schools, shall remain confidential in accordance with 

section 552a of Title 5, United States Code, the confidentiality standards of subsection (c) of 

this section, and sections 444 and 445 of the General Education Provision Act. The study will 

also adhere to requirements of subsection (d) of section 183 prohibiting disclosure of 

individually identifiable information as well as making the publishing or inappropriate 

communication of individually identifiable information by employees or staff a felony. All 

administrative records will be sent to ED’s contractor by TEA using a file transfer protocol (FTP). 

Access to the FTP site will be password protected, and all data will be immediately deleted from 

the FTP site upon successful download by ED’s contractor. All data files will be stored on secure 

server administered by ED’s contractor. Extant student data records will already have been deidentified by TEA prior to transfer. That is, all student identification numbers and school 

identification numbers will have been systematically replaced by TEA using algorithm designed 

by TEA. 

ED’s contractor will protect the confidentiality of all information collected for the study and will 

use it for research purposes only. No information that identifies any study participant will be 

released publicly. Information from participating institutions and respondents will be presented 

at aggregate levels in reports. Information on respondents will be linked to their institution but 

not to any individually identifiable information. No individually identifiable information will be 

maintained by the study team upon study completion.

To protect confidential data, only the contractor’s data management staff, investigators, and 

research staff will have access to the data files on a “need-to-know” basis. Any identifiable 
17

variables, raw data, or derived variables will be stored in encrypted files on a secure data 

management site. Access to this site will be limited to staff assigned to the project. Any data 

obtained for this study will be used only for statistical and descriptive analyses. All identifiers 

will be destroyed as soon as they are no longer required. Study reports will not identify the 

name of any specific analysis unit (e.g., students, school staff members, or schools). In no case 

will information be reported when the total number for a quantity represents fewer than four 

cases. Moreover, any data that permit identity disclosure, when used in combination with other 

known data, will not be published or made available in restricted-use files. 

All members of the study team have obtained their certification on the protection of human 

subjects in research, and REL Southwest staff members will also have obtained federal security 

clearances. The REL study team will submit to the NCEE security officer a list of the names of all 

people who will have access to respondents and data. All staff members working on the project 

who have access to the data or to respondents will be required to sign a confidentiality pledge 

and affidavits of non-disclosure (see copies of the forms in Attachment A-10; we will obtain the 

appropriate signatures). The project team will track new staff and staff who have left the study 

and ensure that additional signatures will be obtained or clearances will be revoked. 

Respondents to the surveys will be informed that project staff are committed to keeping data 

confidential and that participation in the data collection activities is voluntary. Although all of 

the information collected by the survey is publically available information, district identification 

numbers will be scrambled prior to submission of the data to ED in the form of a restricted-use 

file. The instructions for providing extant documents and instructions for online surveys will 

reiterate these points. 

11. Additional Justification for Sensitive Questions

No questions of a highly sensitive nature appear in any instrument, including the online survey. 

In addition, participants will be informed that their responses are voluntary, and they may 

decline to answer any question.

12. Estimates of Hour Burden

There are two components for which ED’s contractor has calculated hours of burden for this 

clearance package: (1) extant data provided by the state to ED’s contractor, and (2) survey data 

collected from study participants by ED’s contractor. Table 3 shows the hourly burden overall 

and for both components. The total burden associated with this study, across three study years, 

is approximately 305 hours, with an annualized burden of 101.7 over three years. This burden 
18

estimate includes the time required for district staff to complete the online survey—273

hours—as well as the burden estimate for extant data collection—32 hours. For this data 

collection, the burden was estimated based on the contractor’s performance of similar survey 

collections and confirmed through pilot testing with TEA staff, as well as the contractor’s 

previous experience obtaining extant data from TEA. To be conservative, the burden estimates 

assume response rates of 100 percent. The annualized number of responses is 343 rounded (a 

total of 1027 across three years), and the annualized number of burden hours is 102 rounded (a 

total of 305 across three years).

Table 3. Time Burden Estimates for the REL Southwest Study of HB 5

Instrument

Person 

Incurring 

Burden

Number of 

Respondents

Responses 

per 

Respondent

Hours per 

Response

Total 

Burden 

(Hours)

1. Extant district staff 

contact information n/a 0 0 0 0

2. District staff survey

(online) District staff 821 1 0.25 205.3

2a. District staff survey

(telephone) District staff 205 1 0.33 67.7

3. Extant student records 

data

State data 

manager

1 2 16 32

Total -- 1027 --

16.5 

(across 

responses)

305

One individual (e.g., district superintendent, district curriculum and instruction director) from each 

Texas public school district will complete the online survey. It is estimated to take no longer than 10

minutes to complete the online version of the survey. We assume an average of 5 minutes per 

respondent for the initial and follow-up emails (a total of 15 minutes for the online survey) and an 

additional 5 minutes for telephone calls (a total of 20 minutes for the telephone survey). 
19

Burden for Extant Data Collection

The total estimated burden for TEA to compile and transmit secondary data to ED’s contractors 

is 32 hours. This calculation assumes one data manager works a collective total of 32 hours (4 

total days) on compiling the data request. We are requesting complete data sets (all variables) 

from the data files maintained by TEA, rather than requesting a customized dataset, which 

would be more time consuming. The complete files will contain extraneous variables, such as 

data flags, variables that provide duplicate data, and variables used to create other variables. 

These extraneous variables will be deleted by ED’s contractor prior to analysis of the data files. 

As such, the burden to downloading the data files and transmitting them to ED’s contractor is 

very low. The extant district staff contact information is public information that is available for 

download from TEA’s website. As such, there are no respondents, no total burden hours, and 

no monetary costs of burden associated with this data collection activity. 

Burden for Survey Data Collection

The total estimated burden for survey data collection for the study is 273 hours, including 205.3 

hours for districts that complete the online survey and 67.7 hours for districts that complete 

the telephone survey. District administrative staff will be surveyed once and asked to complete 

a total of 7-8 questions. The survey will take place during year 1 of the study.

The total cost to respondents for the three components of this study that require data 

collection from outside sources—the district staff survey, the extant district staff contact 

information, and the extant student records data collection—is provided in Table 4. The total 

respondent cost associated with this study is approximately $12,168. The annualized cost for 

this three-year study is $4,056. The cost of the district staff survey is $10,920 ($8212 for the 

online survey; $2708 for the telephone survey); the cost of the extant data collection is $1,248. 

There are no start-up costs associated with this data collection.

Table 4. Estimates of Annualized Costs for Respondents

Tasks Type of Respondent

Total 

Burden 

Hours

Hourly 

Wage 

Rate1

Monetary 

Cost of 

Burden

1. Extant district staff contact 

information None 0 0 $0

2. District staff survey (online) District staff 205.3 $40 $8212 

2a. District staff survey (telephone) District staff 67.7 $40 $2708

3. Extant student records data State data manager 32 $39 $1,248

Total -- 288.5 -- $12,168
20

NOTE: The hourly wage rates for district administrative staff are based on mean wage rates in Texas reported by the 

Bureau of Labor Statistics (2013). For district administrative staff the mean wage for education administrators of 

elementary and secondary schools is used ($39.59). For state data managers the mean wage for statisticians is used 

($38.80). 

13. Estimate of Total Annual Cost Burden to Respondents or Record-Keepers

There are $0 start-up costs associated with this collection. 

14. Estimates of Annualized Cost to the Federal Government

The annualized cost to the federal government for all project activities is $184,333.33. The 

estimated total cost for the three-year project is $553,000.

15. Reasons for Program Changes or Adjustments

This is a new study.

16. Plan for Tabulation and Publication and Schedule for Project

All results for REL studies are made available to the public through peer-reviewed reports that 

are published by IES. The data sets from these studies will be turned over to the REL’s IES 

project officer. These data may become IES restricted-use data sets requiring a user’s license 

that is applied for through the same process as National Center for Education Statistics 

restricted-use data sets (see http://nces.ed.gov/pubs96/96860rev.pdf for procedures related to 

obtaining and using restricted-use data sets). These files will contain all the primary survey data 

collected for the study with all personal identifiers removed. Thorough documentation will be 

provided for each data file, including a detailed codebook and explanations of the unit of 

observation, weights, and methods for handling missing data. The REL contractor also would 

be required to obtain a restricted-use license to conduct any work with the data beyond the 

original report. The extant student records data will not be turned over to the REL’s IES project 

officer. 
21

To answer research questions 1 through 3, we will conduct a series of trend analyses. Our trend 

analyses are designed to investigate changes in algebra II enrollment, algebra II completion, and 

first advanced mathematics course failure rates over time. To do so, we will calculate algebra II 

enrollment, algebra II completion, and first advanced mathematics course failure rates by the 

end of grade 11 over time for students in public high schools in Texas for students who entered 

grade 9 in the 2006-07 through 2014-15 cohorts. Additionally, because the literature shows 

that low-achieving, low-income, and minority students are the least likely to complete a 

rigorous curriculum in high school and the most likely to be influenced by graduation 

requirements, we will also look at whether trends in algebra II enrollment, algebra II 

completion, and third mathematics course failure differ for these subgroups of students. We 

will also look at differences by gender. We will create tables and graphs to present the 

descriptive data.

To answer research question 4 and 5, we will conduct descriptive analyses. Using data from our 

district staff survey, we will describe what districts in Texas are doing in response to HB 5 with 

regard to diploma plan placement, advanced mathematics course offerings, and information 

dissemination about the new graduation requirements. For example, one of the questions on 

the survey ask respondents to indicate which diploma plan, if any students are being placed 

into upon enrollment. We will use descriptive statistics to indicate the number and percentage 

of districts placing students into each diploma plan. These results will also be broken down by 

district characteristics. A companion table will show the number and percentage of students in 

the state being placed into each diploma plan overall and by student characteristics14.

We will also use descriptive statistics to answer research questions 6 and 7. Under HB 5, 

students completing the foundation plus endorsement graduation plan must still complete four 

mathematics courses to graduate. Since students will no longer be required to complete 

algebra II, it will be instructive to see which mathematics courses students choose to complete. 

As such, we will take an in-depth look into students’ mathematics course completion by the end 

of junior year and investigate differences in the types of mathematics courses students 

completed for those students who began grade 9 before and after the implementation of HB 5. 

In particular, we are interested in seeing whether or not students enroll in more 

career/vocational education mathematics courses. To do so, we will group mathematics 

courses into categories, including statistics and probability, vocational mathematics, alternative 

mathematics15, International Baccalaureate mathematics, algebra II, and 

 

14 We will assign all students in the incoming 2014-15 grade 9 cohort within a district into the diploma plan 

indicated by the district administrator. 

15 Under HB 5 several new mathematics courses are being developed, such as algebraic reasoning and other locally 

developed mathematics courses. Additionally, students may complete courses such as mathematical models with 
22

precalculus/trigonometry/calculus, and present frequencies for each category. This approach 

will allow us to determine the types of mathematics courses students are completing by the 

end of their junior year. Then, we will assess differences in the percentages of students 

completing each course type for students who began grade 9 before and after implementation 

of HB 5. As above, we will assess differences in course-type completion by minority status, free 

or reduced-price lunch status, and prior mathematics achievement. We will also look at 

differences between districts that automatically students into the Distinguished Plan and those 

that do not.

The project schedule is presented in Table 5.

Table 5. Schedule of Activities

Activity Date

Draft study proposal to REL Southwest COR May 2014

Revised draft proposal to RPR September 2014

Draft OMB package to COR September 2014

Grade 9 cohort begins high school August 2014

Final study proposal approved by ED November 2014

Project start November 2014

Notice of IRB clearance November 2014

Draft OMB Submission December 2014

Students begin selecting courses for their sophomore year Mid-February 2015

Final OMB approval July 2015

Administer District Survey October/November 

2015

Preliminary data analysis: Course completion data available for students 

who took geometry in grade 9 

July 2016

Students begin selecting courses for their junior year Mid-February 2016

Final data analysis: Course completion data available for all students July 2017

Dissemination of limited distribution memo to TEA Late Summer - Early 

Fall 2017

Dissemination of public reports Late Fall 2017

17. Approval Not to Display the Expiration Date for OMB Approval

Approval not to display the expiration date for OMB approval is not requested.

 

applications, advanced quantitative reasoning, and discrete mathematics for problem solving. All of these 

mathematics courses would fall under the category of “alternative mathematics”. 
23

18. Exception to the Certification Statement

No exceptions to the certification statement are being sought.
24

References

Bureau of Labor Statistics (2013). May 2012 state occupational employment and wage 

estimates: Minnesota. Washington, DC: Author. Retrieved 

http://www.bls.gov/oes/current/oes_mn.htm#00-0000.

U.S. Department of Education. (2010). A blueprint for reform: The reauthorization of the 

Elementary and Secondary Education Act. Washington, DC: Author. Retrieved from 

http://www2.ed.gov/policy/elsec/leg/blueprint/blueprint.pdf
25

Attachment A-1. District Staff Survey 

See attachment
26

Attachment A-2. Follow-up Email

See attachment
27

Attachment A-3. Follow-up Telephone Script

See attachment
28

Attachment A-4. Student Records Data

See attachment
29

Attachment A-5. IRB Approval

See attachment
30

Attachment A-6. Educational Sciences Reform Act (ESRA)

See attachment
31

Attachment A-7. Federal Register Notices

See attachment
32

Attachment A-8. Confidentiality Form and Affidavits

See attachment
33

Attachment A-9. Technical Working Group Suggestions

See attachment