2015-16 NATIONAL POSTSECONDARY 

STUDENT AID STUDY (NPSAS:16)

Field Test Institution Contacting 

and Enrollment List Collection

Supporting Statement Part A

(OMB # 1850-0666 v.12)

Submitted by

National Center for Education Statistics

U.S. Department of Education

March 2014
iii

Contents

A. Justification ......................................................................................................................................5

1. Circumstances Making Collection of Information Necessary...................................................................... 5

a. Purpose of this Submission ........................................................................................................................ 5

b. Legislative Authorization ............................................................................................................................ 6

c. Prior NPSAS Studies ................................................................................................................................... 6

d. Prior and Related Studies............................................................................................................................ 7

2. Purposes and Uses of the Data.......................................................................................................................... 7

a. NPSAS:16 Purposes..................................................................................................................................... 7

b. NPSAS:16 Research and Policy Issues ..................................................................................................... 8

3. Use of Information Technology......................................................................................................................10

4. Efforts to Identify Duplication........................................................................................................................10

5. Method Used to Minimize Burden on Small Businesses ............................................................................10

6. Frequency of Data Collection..........................................................................................................................11

7. Special Circumstances of Data Collection.....................................................................................................11

8. Consultants Outside the Agency .....................................................................................................................11

9. Provision of Payments or Gifts to Respondents..........................................................................................11

10. Assurance of Confidentiality............................................................................................................................11

11. Sensitive Questions............................................................................................................................................14

12. Estimates of Response Burden........................................................................................................................14

13. Estimates of Cost...............................................................................................................................................15

14. Costs to Federal Government .........................................................................................................................15

15. Reasons for Changes in Response Burden and Costs .................................................................................17

16. Publication Plans and Time Schedule.............................................................................................................17

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

18. Exceptions to Certification for Paperwork Reduction Act Submissions.................................................17

B. Collection of Information Employing Statistical Methods...................Error! Bookmark not defined.

C. Information Collected on Enrollment Lists..........................................Error! Bookmark not defined.

D. References.............................................................................................Error! Bookmark not defined.

Appendixes

A. Previous Studies Based on NPSAS, B&B, and BPS Data

B. Technical Review Panel (TRP) Members

C. Confidentiality Agreement

D. Respondent Communication Materials – Letters

E. Respondent Communication Materials – Phone Script

F. Anticipated Endorsing Associations for NPSAS:16

Tables Page

1. Chronology of NPSAS and its longitudinal components.......................................................................... 7

2. Maximum estimated burden on institutions for the NPSAS:16 field test enrollment list collection15

3. Individual and total costs to NCES for the NPSAS:16 field test and full-scale implementations.... 15

4. Contract costs for NPSAS:16....................................................................................................................... 16

5. Operational schedule for NPSAS:16........................................................................................................... 17

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A. Justification

1. Circumstances Making Collection of Information Necessary

a. Purpose of this Submission

This document supports the clearance of selected materials and procedures for institution sampling and 

contacting, and enrollment list collection for the field test of the 2015-16 National Postsecondary Student Aid 

Study (NPSAS:16). A separate request for review pertaining to the student record data abstraction and 

student interview will be submitted in the fall of 2014. This study is being conducted by the National Center 

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

Department of Education. The primary contractor for this study is RTI International (Contract# ED-IES-13-

C-0070), and subcontractors include Coffey Consulting; Hermes; HR Directions; Kforce Government 

Solutions, Inc.; Research Support Services; Shugoll Research; and Strategic Communications, Inc. Consultants 

are Dr. Sandy Baum and Ms. Alisa Cunningham.

This submission requests reinstatement of the previously obtained clearance for the 2011-12 cycle of NPSAS 

(OMB No. 1850-0666 v.8-11). This submission covers NPSAS:16 field test materials and procedures related 

to institution sampling, institution contacting, enrollment list collection, and enrollment list sampling. 

Following the field test study in 2015, NCES will provide the Office of Management and Budget (OMB) with 

a memorandum summarizing any changes planned for the full-scale data collection, and a revised OMB 

package. The materials that will be used in the 2015-16 full scale 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 full scale study.

NPSAS:16 is a nationally representative study of how students and their families finance education beyond 

high school. NPSAS was first implemented by NCES during the 1986–87 academic year to meet the need for 

national-level data about significant financial aid issues. Since 1987, NPSAS has been fielded every 3 to 4 

years, most recently during the 2011–12 academic year. This submission is for the ninth cycle in the series that 

will be conducted during the 2015–16 academic year. NPSAS:16 also will serve as the base year data collection 

for the 2016 Baccalaureate and Beyond Longitudinal Study (B&B), a study of college graduates one year 

(B&B:16/17), four years (B&B:16/20), and ten years (B&B:16/26) following completion of the bachelor’s 

degree. Subsets of questions in the student interview will focus on describing aspects of the experience of 

B&B-eligible students in their last year of postsecondary education, including student debt, entry to graduate 

school, and the transition to employment and career. 

This submission includes:

 A list of previous studies related to or based on data from NPSAS or its longitudinal spin-offs 

(Appendix A);

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

of NPSAS:16 (Appendix B);

 The Confidentiality Agreement completed by all project staff having access to individually identifiable 

data (Appendix C);

 Introductory letters to institutions and students selected for participation in the NPSAS:16 study 

(Appendix D);

 The script used by institutional contactors to verify eligibility and confirm contact information with 

sampled institutions (Appendix E); and

 A list of anticipated endorsing institutions and associations supporting NPSAS:16 (Appendix F). 
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b. Legislative Authorization

NPSAS:16 is conducted by NCES in close consultation with other U.S. Department of Education offices, 

federal agencies, and organizations. NPSAS is authorized under the Education Sciences Reform Act (ESRA) 

of 2002 (20 U.S.C. § 9512) and the Higher Education Opportunity Act (HEOA) of 2008, 20 U.S.C. § 1015:

(A)(k) Student aid recipient survey 

(1) Survey required: The Secretary, acting through the Commissioner for Education Statistics, shall conduct, on a Stateby-State basis, a survey of recipients of Federal student financial aid under Title IV—

(A) to identify the population of students receiving such Federal student financial aid; 

(B) to describe the income distribution and other socioeconomic characteristics of recipients of such Federal student 

financial aid; 

(C) to describe the combinations of aid from Federal, State, and private sources received by such recipients from all 

income categories; 

(D) to describe the—

(i) debt burden of such loan recipients, and their capacity to repay their education debts; and 

(ii) the impact of such debt burden on the recipients’ course of study and post-graduation plans; 

(E) to describe the impact of the cost of attendance of postsecondary education in the determination by students of 

what institution of higher education to attend; and 

(F) to describe how the costs of textbooks and other instructional materials affect the costs of postsecondary 

education for students. 

(2) Frequency: The survey shall be conducted on a regular cycle and not less often than once every four years. 

(3) Survey design: The survey shall be representative of students from all types of institutions, including full-time and 

part-time students, undergraduate, graduate, and professional students, and current and former students. 

(4) Dissemination: The Commissioner for Education Statistics shall disseminate to the public, in printed and electronic 

form, the information resulting from the survey.

c. Prior NPSAS Studies 

As noted above, NPSAS:16 will be the ninth NPSAS in a series dating back to 1986–87. The first in 

the series, NPSAS:87, based on a sample of students enrolled in the fall term of 1986, is not completely 

comparable to later studies. Beginning in 1989–90, NPSAS surveys sampled students enrolled at any time 

during a full academic year, so that students enrolled only during the summer or spring terms, as well as those 

who began at any time in institutions (primarily vocational) not on a traditional calendar system, were 

included. In NPSAS:87 and NPSAS:12, institutions in Puerto Rico were not sampled. Additional detailed 

information about each of the prior NPSAS studies and related longitudinal studies conducted by NCES can 

be found at http://nces.ed.gov/surveys/npsas/.

Since its inception, the data collection techniques, sources, and sampling and weighting methods used 

for NPSAS have evolved to meet new demands for more precise and detailed information to inform 

postsecondary student financial aid policy. Following NPSAS:87, which combined paper-based surveys of 

40,000 students and a subset of their parents with institutional records, NPSAS:90 introduced computerassisted telephone interviewing and incorporated data from the federal Pell Grant payment file. NPSAS:93 

enabled institutions to enter student records electronically, and NPSAS:96 added as data sources the Central 

Processing System for federal financial aid applications, the National Student Loan Data System, and SAT 

and ACT student test scores. NPSAS:2000 dropped the parent interview and expanded the sample size to 

60,000 students. NPSAS:04 introduced a self-administered web-based student interview option, further 

increased the sample size to 110,000 students, and for the first time oversampled undergraduate students in 

12 states to permit state-representative estimates for those states. NPSAS:08 retained state-representative 

oversamples for six states, enlarged the sample size to 130,000 students, and added the National Student 

Clearinghouse (NSC) as an administrative data source. NPSAS:12, in response to the growing for-profit 

sector and to ensure reliable estimates at all institution levels, dropped the state-representative samples, but 

added separate sampling for all levels of the for-profit sector: less-than-2-year, 2-year, and 4-year institution. 

In addition, NPSAS:12 was the first cycle to use current-year 12-month institutional enrollment data to ensure 

more accurate poststratification (weighting) than using prior-year enrollment data.
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d. Prior and Related Studies

Two longitudinal studies conducted within the Sample Surveys Division of NCES were designed to address a 

variety of issues regarding higher education. Based on samples of students attending postsecondary education 

in a particular year regardless of age, each of these studies incorporates base year data from the cross-sectional 

NPSAS and extends it through longitudinal follow-up components focusing on first-time students and on 

recent college graduates in alternate NPSAS survey years: Beginning Postsecondary Students (BPS) and 

Baccalaureate and Beyond (B&B). The chronology of the previous administrations of the NPSAS study and 

its associated longitudinal components is presented in table 1.

Table 1. Chronology of NPSAS and its longitudinal components

Base year First follow-up Second follow-up Third follow-up

NPSAS:90 BPS:90/92 BPS:90/94 —

NPSAS:93 B&B:93/94 B&B:93/97 B&B:93/03

NPSAS:96 BPS:96/98 BPS:96/01 —

NPSAS:2000 B&B:2000/01 — —

NPSAS:04 BPS:04/06 BPS:04/09 —

NPSAS:08 B&B:08/09 B&B:08/12 —

NPSAS:12 BPS:12/14 BPS:12/17 —

NPSAS:16 B&B:16/17 B&B:16/20 (anticipated)

— Not applicable.

NOTE: BPS = Beginning Postsecondary Students; B&B = Baccalaureate and Beyond.

The seven major issues addressed in these Sample Surveys Division studies are:

1. Undergraduate access/choice of institution;

2. Persistence;

3. Progress/curriculum;

4. Attainment/outcome assessment;

5. Financial aid and student debt;

6. Access to graduate programs; and 

7. Benefits of postsecondary education to individuals and society.

Specific studies that explore some of these issues and have been based on previous NPSAS, BPS, or B&B 

data are listed in appendix A for reference.

2. Purposes and Uses of the Data

This section provides information on the purposes of NPSAS, and an overview of the primary research issues 

it addresses.

a. NPSAS:16 Purposes

The fundamental purpose of NPSAS is to create a research data set that brings together information about a 

variety of programs for a large sample of undergraduate and graduate students. NPSAS provides the data for 

comprehensive descriptions of the undergraduate and graduate student populations in terms of their 

demographic characteristics, academic programs, types of institutions attended, attendance patterns, and 

employment. Demographic and enrollment data establish the appropriate context that allows researchers and 

policy analysts to address basic issues about postsecondary affordability and the recipients of student financial 

assistance. These results are presented in two First Look reports and four Web Tables publications: an 

overview of student aid by institutional sector, a profile of undergraduates, a detailed description of 

undergraduate financing, and a profile of graduate students and the financing of their education beyond the 

bachelor’s degree. In addition, an undergraduate financing report describes the total price of attendance for 

undergraduates (tuition and fees plus non-tuition expenses), the net price after grant aid, and the “out-ofpocket” net price (after all aid, including loans). The data can be used to calculate statistics with PowerStats 
8

and QuickStats, two web-based software applications available to the public at http://nces.ed.gov/datalab, 

and to qualified researchers through the IES restricted-use data licensing program.

A second purpose of NPSAS is to gather base-year data on a subset of students who become the sample for a 

longitudinal study. NPSAS:16 will establish the base year cohort for a B&B study of bachelor’s degree 

recipients, with a follow-up survey one year later (B&B:16/17) and additional follow-ups anticipated in 2020 

and 2026. A section of the student interview will capture information about students’ graduate school and 

career plans to support analysis of graduate education and employment outcomes. 

A third purpose of NPSAS is to provide a nationally representative sample that can be used to rigorously 

address fundamental research questions through experimental research methodologies. NCES plans to 

expand the use of NPSAS through collaboration with the National Center for Education Research (NCER). 

NPSAS provides a rich source of data that could potentially be used to support experimental research funded 

by NCER. Interested researchers will be asked to submit a proposal that details their experimental design and 

analysis plans. Upon grant review and approval, RTI will conduct any needed data collection and/or filematching activities and deliver a restricted data file to NCES to provide to the grantee for analysis. More 

detail about the possibility of working with NCER will be provided in the forthcoming request for OMB 

approval of student data collection in the fall of 2014.

b. NPSAS:16 Research and Policy Issues

Many of the important questions that NPSAS:16 aims to address are the same as in the past years. Price 

increases, net price levels, and increases in student loan debt will continue to be central issues. The NPSAS:16 

data will be used to address policy issues related to the changes in federal financial aid programs resulting 

from the anticipated reauthorization of the Higher Education Act. Some of the primary research and policy 

issues to be addressed through the use of NPSAS:16 data will likely be: 

(1) Student demographics;

 What is the distribution of student enrollment among types of institutions by gender, 

race/ethnicity, age, dependency, and income?

 What types of institutions are serving the largest proportions of low-income, non-traditional, and 

ethnic minority students?

 What proportion of undergraduates are first generation college students, and what types of 

institutions are they attending?

 What proportion of students are immigrants or children of immigrants, and what types of 

institutions are they attending?

 How much are students with disabilities participating in postsecondary education?

 What proportion of students enrolled in postsecondary education are active military or veterans 

and what types of institutions do they attend?

(2) Academic preparation and programs;

 What proportion of college students have taken remedial courses and in what subjects? 

 What types of students are enrolled in vocational certificate, associate’s, and bachelor’s degree 

programs, and what are their fields of study?

 What is the extent of internet-based and other distance education, for certain courses or for 

entire programs of study, and what types of institutions and students are using it?

 What are students’ primary purposes for enrolling in postsecondary education and their 

educational goals?

(3) Financial aid;
9

 What proportion of students has financial aid need and what is the average amount of need by 

income?

 What proportion of students has remaining need beyond what they receive in financial aid and 

what is the average amount of unmet need?

 What proportion of students receives Federal Pell grants and where do they attend college?

 What proportion of students are receiving aid from states, institutions, employers, and private 

sources, and what is the average amount received?

 What proportion of students is receiving need-based or merit-based aid? 

 How does the amount and type of aid vary by dependency and income level?

 What is the ratio of federal to non-federal aid at various types of institutions?

 What is the ratio of grants to loans at various types of institutions?

 What proportion of students receives veterans and other Department of Defense benefits, and 

how much do they receive?

 How has the incidence and average amount of Veterans’ benefits changed since the enactment of 

the Post-9/11 GI Bill (P.L. 110-252)?

 How has the number and proportion of nonveterans receiving Veterans’ benefits as dependents 

of veterans changed since enactment of the Post-9/11 GI Bill (P.L. 110-252)? 

 What types of institutions enroll the highest proportions of active military personnel, veterans, 

and recipients of Veterans’ benefits?

(4) Price of attendance;

 What are the differences in the average tuition and total price of attendance by type of institution 

and among students by dependency, income, and full-time or part-time attendance status? 

 What is the average net price of attendance (student budget minus financial aid) at various 

income levels at different types of institutions?

(5) Student borrowing;

 What are the differences in the percentage borrowing and the average amounts borrowed 

through the federal student loan programs by institution type, attendance status, class level, and 

income?

 What proportion of students borrow the maximum Direct (Stafford) loan amounts? 

 What is the difference in the proportion of students receiving subsidized or unsubsidized Direct 

(Stafford) loans by dependency and income level?

 What is the average cumulative debt of students by class level, especially among graduating 

college seniors?

 What proportion of students borrows private loans, in what amount, and how does this 

borrowing vary by institution type?

 What proportion of students use credit cards to finance their education, and how much do they 

borrow?

(6) Student employment;

 What proportion of students engage in paid work while enrolled and what are the average hours 

per week they work?

 What is the average amount earned from work while enrolled?
10

 What proportion of students is employed by their institution in work-study and graduate 

assistantships as compared with other types of employment?

(7) Sources of funds;

 What types of financial support are dependent students receiving from their parents?

 What is the estimated proportion of students who might benefit from the federal education tax 

benefits (such as the American Opportunity and Lifetime Learning tax credits) based upon family 

income, tuition paid, and grant aid received?

Answers to these and other questions are vital if policymakers at the local, state, and national levels are to 

respond adequately to the changing environment of postsecondary education. As the publications listed in 

appendix A indicate, since inception, the NPSAS, BPS, and B&B series have resulted in numerous NCES 

publications addressing these issues. The data from these studies have also been used extensively to explore 

Sample Surveys division issues through the NCES Postsecondary Analysis Resources (PEAR) series.

3. Use of Information Technology

To ensure the secure transmission of sensitive information on the student enrollment lists, we will allow 

institutions to either upload encrypted student enrollment list files to the project’s secure website using a login 

ID and “strong” password provided by RTI, or provide an appropriately encrypted list file via e-mail (RTI

will provide guidelines on encryption and creating “strong” passwords). 

We do not expect that institutions will ask to provide a paper list, but the data security plan will outline 

protocols for handling faxed materials that conform to data security requirements. The original file or paper 

list containing all students with Social Security numbers (SSNs) will be kept through data collection in order 

to resolve any issues with student identification that occur during data collection. These files will be deleted 

and lists shredded after data collection. RTI will ensure that the SSNs for non-selected students are securely 

discarded. 

4. Efforts to Identify Duplication

Efforts to identify duplication have included NCES consultations with other federal offices, such as the 

Department’s Office of Postsecondary Education; the Office of Planning, Evaluation and Policy 

Development; and other agencies, such as the National Science Foundation; the Congressional Budget Office;

and the Office of Management and Budget. NCES also routinely consults with non-federal associations such 

as the American Council on Education; the Association of Private Sector Colleges and Universities; the 

National Association of Student Financial Aid Administrators; the National Association of Independent 

Colleges and Universities; the Council of Graduate Schools; and the Institute for Higher Education Policy to 

confirm that the data to be collected through NPSAS are not available from any other sources. Academic 

researchers are also consulted, with several attending NPSAS Technical Review Panel meetings along with

representatives from federal agencies, associations, and postsecondary institutions. Beyond identification of 

duplication, these consultations provide methodological insights from the results of similar and related studies 

conducted by NCES, other federal agencies, and nonfederal sources. The consultations also assure that the 

data collected through NPSAS will meet the needs of the federal government and relevant organizations. 

There are no other studies in the U.S that duplicate the data produced by NPSAS.

5. Method Used to Minimize Burden on Small Businesses 

The burden associated with enrollment list collection is relatively minor for all institutions, including small 

businesses that may be contacted as part of the NPSAS:16 field test (for-profit schools and other small public 

and private schools). NPSAS:16 is asking for a minimal set of variables on the enrollment lists, and 

institutions will be offered alternative methods of providing requested data, including uploading to a secure 

website or emailing encrypted list files. We will attempt to minimize the intrusion and burden to such schools 
11

by working closely with a school-appointed coordinator before the data collection effort to identify the 

sources of information within the school and the format in which records are kept. We have also discussed 

enrollment list variables with the technical review panel to ensure that the request is minimally burdensome 

and consistent with typical recordkeeping at postsecondary institutions.

6. Frequency of Data Collection

This cycle of NPSAS will take place 4 years after the last data collection. The large-scale and rapid changes in 

federal policy concerning postsecondary student aid necessitate frequent studies. Eligibility restrictions 

change, size of grant and loan amounts fluctuate, and the balance between various aid options changes 

dramatically. Since these changes affect students’ ability to finance postsecondary education and the level of 

debt that students are accumulating, data collections every 3 to 5 years are necessary. A recurring study is 

essential in helping predict future costs for financial aid because loan programs create continued obligations 

for the federal government as long as the loans are being repaid.

Repeated surveys, such as NPSAS, are also necessary because of the dynamic nature of the postsecondary 

environment. For example, for-profit institutions have recently assumed a much more prominent role than 

was the case in years past. Changes in private-sector lending, increases in tuition and fees, and changes in 

federal student aid policies (such as the recent increase in maximum Pell Grant awards) further highlight the 

need for periodic data collections. Effects of these changes on federal policy and postsecondary education 

participation create an opportunity, as well as a need, for monitoring on a regular basis.

7. Special Circumstances of Data Collection

No special circumstances of data collection are anticipated. 

8. Consultants Outside the Agency

Recognizing the significance of NPSAS data collection, several strategies have been incorporated into the 

project work plan that allow for the critical review and acquisition of comments relating to project activities, 

interim and final products, and projected and actual outcomes. These strategies include consultations with 

persons and organizations both internal and external to NCES, the U.S. Department of Education, and the 

federal government. 

Previous NPSAS implementations have benefited from a technical review panel composed of staff from 

several offices in the Department, representatives of OMB and CBO, and non-federal members who are 

considered experts in issues in postsecondary education, including financial aid. Several meetings of the 

NPSAS:16 technical review panel are planned. The institution data collection TRP (see appendix B) has 

already provided expert review of the institution contacting procedures and variables to be collected during 

the enrollment list collection. A second TRP, with some overlap in membership, will review plans for the 

field test study design and key topics during a summer 2014 meeting, and will review plans for the full-scale 

study design during a meeting planned for summer 2015. Subsequent to the TRP meeting, a separate request 

for OMB review related to student-level data collection activities, specifically, the student interviews and 

student record collection from institutions, will be submitted in the fall 2014.

9. Provision of Payments or Gifts to Respondents

No payments or gifts to responding institutions will be given. 

10. Assurance of Confidentiality

NCES assures participating individuals and institutions that any data collected under NPSAS and related 

programs shall be in total conformity with NCES’s standards for protecting the confidentiality of identifiable 

information about individuals [Education Sciences Reform Act (ESRA); 20 U.S.C. § 9573(a)]. The Family 

Educational Rights and Privacy Act (FERPA), (34 CFR Part 99) allows the disclosure of information without 
12

prior consent for the purposes of NPSAS:16 according to the following excerpts: 99.31 asks “Under what 

conditions is prior consent not required to disclose information?” and explains in 99.31 (a) “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 specific conditions. The NPSAS:16

collection falls under: 

Sec. 99.31 (a)( 3). The disclosure is, subject to the requirements of Sec. 99.35, to authorized representatives of--

(i) The Comptroller General of the United States;

(ii) The Attorney General of the United States;

(iii) The Secretary; or

(iv) State and local educational authorities. 

RTI and its subcontractors will secure all data and protect the confidentiality of all participants in NPSAS. 

Data security and confidentiality protection procedures are in place to ensure that the contractor complies 

with all privacy requirements, including: 

 The Statement of Work of this contract;

 Privacy Act of 1974 5 U.S.C. § 552(a) (2009);

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

 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 and Privacy Act of 1974, 20 U.S.C. § 1232(g) (2009);

 ESRA, 20 U.S.C. §§ 9573 (2009); and

 Any new legislation, which impacts the data collection through this contract. 

RTI will also 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 revised NCES Statistical Standards, as described at 

the website: http://nces.ed.gov/statprog/2012/.

The NPSAS:16 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. NPSAS:16 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. We do not anticipate 

receiving enrollment lists via fax, but any that are received will be securely shredded upon study completion. 

Electronic enrollment lists will reside within an independent secure network, and be deleted upon study 

completion. 

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 
13

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. The confidentiality agreement

related to these security features is provided in appendix C.

Study notification materials sent to institutions will describe the voluntary nature of the NPSAS:16 survey 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 2015-16 National Postsecondary Student Aid Study is conducted under the authority of the Higher 

Education Opportunity Act (HEOA) of 2008 (20 U.S.C. § 1015) and the Education Sciences Reform 

Act (ESRA) of 2002 (20 U.S.C. § 9512) which authorize NCES to collect and disseminate information 

about education in the United States. Collection is most often done through surveys. 

NCES is required to follow strict procedures to protect the confidentiality of persons 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, unless otherwise compelled by law (20 U.S.C. § 9573).

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 National Student Clearinghouse (NSC) which has its own secure FTP site. 

All data transfers will be encrypted using FIPS 140-2 validated encryption tools.

Regarding file matching with administrative sources, FERPA (34 CFR Part 99) allows the disclosure of 

information without prior consent for the purposes of NPSAS:16 according to the following excerpts: 99.31 

asks “Under what conditions is prior consent not required to disclose information?” and explains that (a) “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 the following 

conditions:

(6)(i) 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, 99.31 (a)(6)(iv) 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 99.31(a)(6)(i) apply to NPSAS:16. The purpose of NPSAS:16 is to create a research data set 

for a large sample of students that brings together information about federal, state, and private aid programs, 

and gathers additional demographic and enrollment data to establish the appropriate context. The resultant 

data set allows research and policy analysts to address basic issues about the affordability of postsecondary 

education and the effectiveness of the existing financial aid programs. The data set can be used for, or on 

behalf of, educational agencies or institutions to accomplish activities (A), (B), and (C).

FERPA 99.31 (a) (6) 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. 

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

based on the following factors:
14

 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 RTI’s

contract, 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.

 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 from the study is important enough to justify the waiver. These linked data for 

NPSAS:16 will provide invaluable data to researchers and education policy makers about the federal 

financial aid that students have received, as well as critical information concerning access to and 

persistence in postsecondary education. Rather than ask students for information about financial aid, we 

are getting it from the NSLDS, which is the Department’s system of recording federally aided student 

loans taken out by students and grants received. In NCES's experience, students are generally not a very 

reliable source of information about the amounts or timing of grants and loans they have received. This 

administrative record data is accurate and much easier to obtain than by administering a questionnaire.

As part of initial sampling activities, we will ask participating institutions to provide SSNs for all students on 

their enrollment list. Having an initial list of all student SSNs minimizes the time and burden on both the 

institutions and the contractor. Institutions will only have to provide one enrollment list; if the SSNs were 

provided only for those students selected, the institutions would have to provide two separate enrollment 

lists. Immediately after the student sample is selected, the SSNs for non-selected students will be securely 

discarded.

11. Sensitive Questions

Institutions will be asked to provide personally-identifying information for students on the enrollment lists 

(including name, contacting information, SSN, and date of birth (DOB)). Although considered sensitive, 

items collected on the enrollment lists will facilitate 1) identification of minors in the sample, 2) selection of 

the student sample, 3) initial tracing and locating activities, and 4) ongoing follow up with the baccalaureate 

cohort as part of the Baccalaureate and Beyond Longitudinal Study. Immediately after the student sample is 

selected, the SSNs for non-selected students will be securely discarded. 

12. Estimates of Response Burden 

Projected estimates for response burden and costs for NPSAS:16 are based on experiences from prior rounds 

of NPSAS. Using time burden data for similar institutional data collection tasks, we estimate the average 

burden associated with the enrollment list collection to be approximately 2.75 hours per institution. The 

estimated hourly cost to institutions was raised from $17 for NPSAS:12 to $21 for NPSAS:16 to reflect salary 

increases at those institutions. The total estimated cost to institutions participating in the NPSAS:16 field test 

enrollment list data collection for the 724 total burden hours is $15,204. This submission is for field data 
15

collection of institution materials and enrollment lists only. Burden estimates for data collection from and 

about sampled students will be submitted in a separate package in fall 2014.

The response time for participating institutions is expected to vary based on how institutions keep their 

records and how easily they can extract the requested information. First, eligibility screening calls will be made 

to each sampled institution to confirm eligibility and verify contact information prior to mailing study 

information. Next, eligible institutions will be asked to complete an Institution Registration Page (IRP) to 

provide basic information about institutional characteristics. Finally, institutional coordinators will be asked to 

provide electronic enrollment lists of all students enrolled during the academic year. Institutions will be 

offered two methods for providing their enrollment lists:

1. Upload encrypted student enrollment list files to the project’s secure website using a login ID and 

“strong” password provided by RTI, or 

2. Email an appropriately encrypted list file directly to RTI.

Based on NPSAS:12 full-scale results, we expect that most NPSAS:16 enrollment lists will be uploaded to the 

project website, and very few enrollment lists will be sent via e-mail.

Table 2. Maximum estimated burden on institutions for the NPSAS:16 field test enrollment list collection

Data collection activity

Institution 

sample

Expected 

eligible 

institutions

Number of 

responding 

institutions

Percent 

expected 

response 

rate

Average time 

burden per 

response 

(hours)

Range of 

response 

times 

(hours)

Total time 

burden 

(hours)

NPSAS:16 field test study

Eligibility screening calls 300 290 300 † .08 .03-.10 24

Institutional registration page † 290 247 85 .08 .05 -.11 20

Institutional enrollment lists † 290 247 85 2.75 1.0-6.0 680

Field test Institutional total 300 (794 responses) 724

† Not applicable.

13. Estimates of Cost

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

printing, or postage charges will be incurred. 

14. Costs to Federal Government

A summary of estimated costs to the federal government for NPSAS:16, shown in table 3, are categorized by 

field test, full-scale study, and total costs. 

Table 3. Individual and total costs to NCES for the NPSAS:16 field test and full-scale implementations 

NPSAS:16 implementations Costs to NCES

Field test

NCES Salaries and expenses $62,370 

Contract costs 7,173,724

Total 7,236,094 

Full-scale study

NCES Salaries and expenses 197,739 

Contract costs 13,574,629 

Total 13,772,368 

Total costs

NCES Salaries and expenses 260,109 

Contract costs 20,748,353 

Total $21,008,462 

NOTE: Costs presented here do not include base fee.
16

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 (although this 

request is for field test institution contacting and enrollment list collection, the costs shown here are for the 

full study, including institution and student data collection efforts; request for field test student data collection

will be submitted in fall 2014). Table 4 provides a more detailed breakdown of contract costs.

Table 4. Contract costs for NPSAS:16 

Study area and task Budgeted amount

110 Post award conference $25,400 

120 Schedules 26,353

130 Monthly reports 215,474

140 Integrated monitoring system 544,143

150 Technical review panels 1,286,662

160 Mini-meetings 135,116

Standardized institution data collection

210 Task 2 Comparison Report 323,667

220 Institution Data Reporting System 358,575

Field test data collection

310 Sampling 379,416

320 OMB forms clearance 141,586

321 Instrument development 1,776,265

322 Training 336,001

323 Tracing 99,365

324 Student data collection 738,821

325 Student data processing 489,743

332 CPS file merge 19,479

333 NSLDS file merge 11,573

334 Other system file merge 73,373

335 Develop data collection materials 161,337

340 Methodology memorandum 202,961

351 Enrollment list collection 612,974

352 Institution data collection 155,653

353 Institution data processing 237,622

Full-scale data collection

410 Sampling 474,362

420 OMB forms clearance 105,070

421 Instrument development 1,048,446

422 Training 406,704

423 Tracing 605,531

424 Data collection 4,432,465

425 Interview data processing 1,262,758

432 CPS file merge 50,053

433 NSLDS file merge 34,463

434 Other system file merge 218,940

435 Develop data collection materials 111,009

436 Weighting, imputation, and nonresponse bias analysis 212,304

437 Data disclosure 29,388

441 Enrollment list collection 698,939

442 Institution data collection 462,466

443 Institution data processing 759,727

Reporting

511 Report prospectus 57,125

512 Draft manuscript 245,997

513 Review-quality manuscript 151,531

514 Public-ready manuscript 90,942

515 Respond to professional judgment 19,789

610 Respond to information requests 564,165

620 Major IT data reporting 242,693

630 Ad hoc reports 111,926

Total $20,748,353
17

15. Reasons for Changes in Response Burden and Costs

There has been no change in burden per institution since the full-scale data collection for NPSAS:12. This 

request for approval is for the field test data collection from institutions only, with approval for data 

collection from students to be sought later this year.

16. Publication Plans and Time Schedule

The operational schedule for the NPSAS:16 field test and full-scale study is shown in table 5. The formal 

contract for NPSAS:16 requires the following reports, publications, and other public information releases:

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

 Detailed data file documentation describing all aspects of the full-scale 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 a restricted-file; 

QuickStats, a public-use data analysis system in which users create their own tables and charts using 

pre-defined categories from a subset of variables; and PowerStats, which allows users to create their 

own tables and charts using all of the variables, in addition to conducting regression analysis;

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

Table 5.Operational schedule for NPSAS:16

NPSAS:16 activity Start date End date

Field test

Contacts with institutions to request enrollment lists Sept. 15, 2014 Feb. 3, 2015

Enrollment list collection Jan. 29, 2015 Jul. 31, 2015

Select student sample1

Jan. 30, 2015 May 14, 2015

Collect student data from institution records Mar. 2, 2015 Jun. 30, 2015

Self-administered web-based data collection Mar. 2, 2015 Jun. 30, 2015

Conduct telephone interviews of students Mar. 23, 2015 Jun. 30, 2015

Process data, construct data files Feb. 13, 2015 Aug. 31, 2015

Prepare/update field test reports May 4, 2015 Dec 18, 2015

Full-scale study

Contacts with institutions to request enrollment lists Oct. 1, 2015 Feb. 26, 2016

Enrollment list collection Jan. 11, 2016 Jul. 10, 2016

Select student sample Jan. 18, 2016 Jun. 1, 2016

Collect student data from institutional records Feb. 1, 2016 Sept. 30. 2016

Self-administered web-based data collection Feb. 1, 2016 Sept. 30, 2016

Conduct telephone interviews of students Feb. 22, 2016 Sept. 30, 2016

Process data, construct data files Jan. 22, 2016 Jun. 14, 2017

Prepare/update reports Aug. 1, 2016 July 31, 2018

17. Approval to Not Display Expiration Date for OMB Approval

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

instruments and materials. No special exception is being requested.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

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

Reduction Act Submissions of OMB Form 83-I.

 

1

Student samples will be selected from lists received by May 8, and the remaining lists will be used for a methodological test (see 

section B2 for more details).