1

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) 

### SUPPOR **TING ST AT**  **EMENT FOR P**  **APER WORK REDUCTION**  **ACT SUBMISSION Gainful Employment Recent Graduates Employment and Earnings Survey**  **Pilot Test**
**A. Justification** 1. Explain the circumstances that make the collection of information necessary . Identify any legal or administrative requirements that necessitate the collection. Attach a hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The National Center for Education Statistics (NCES) of the U.S. Department of Education (ED) is required by regulation to develop an earni ngs survey to support gainful employ ment program evaluations (see 34 CFR 668.406 as specified in final regulations published in the Federal Register in October 2014). NCES is responsible for developing the survey

and the technical standards to which programs must adhere in its administration. The first round of cognitive interviews for this development effort and recruitment for the second round were approved separately in January

2015 (#1850

- 0803 v.123 and v. 125, respectively); a separate request to condu ct the second round of cognitive testing was approved in March (#1850

- 0803 v. 130). This request is to conduct a pilot test of the Recent Graduates Emplo ym ent and Earnings Survey (RGEES). The data collection for this study is being carried out under contra ct to NCES by RTI International (contract # ED

- IES

- 13

- C

- 0070). Postsecondary

programs subject to the gainful employ ment regulations may

appeal program - level debt

- to

- earnings ratios calculated by ED (34 CFR Parts 600 and 668). The earnings component of the debt

- to

- earnings ratio (D/E ratio) is provided b y the Social Security Administration, but institutions may calculate an alternative earnings measure by administering a survey

to program graduates. Institutions that choose to submit alternate earnings appe al information will survey all students from programs who graduated during the same period that ED used to calculate the D/E ratios, or a comparable period as defined in 668.406(b)(3) of the regulations. The survey will provide an additional source of earn ings data for ED to consider before deciding on final D/E ratios for programs subject to the gainful employment regulations. Programs with final D/E ratios that fail to meet the minimum threshold may face sanctions, including the possible loss of Title IV (federal financial aid) program funds. The regulations specify

that the Secretary

of Education will publish in the Federal Register a pilot

- tested earnings survey and the standards required for its administration. The draft standards are being published f or public comment in a separate announcement.

1 Plea se limit pasted text to no longer than 3 paragraphs.2

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) In preparation for this submission, NCES reviewed existing person

- level survey s conducted regularl y b y the United States Census Bureau (Census) and the Bureau of Labor Statistics (BLS) for data collection appro aches and item sets, and organized meetings that included these agencies. Representatives from Census included Charles Nelson (Assistant Division Chief of the Economic Characteristics Division at Census) and Alfred Gottschalk (Chief of the Labor Force Stat istics Branch at Census). Anne Polivka, Chief of the Statistics Employ ment Research Division, represented BL S. I n addition, Katharine Abraham, former director of BL S and a recent member of the President’s Council of Economic Advisors, was instrumental in r evisions to items that are included in this submission. Appendix 1 below provides item source annotations referencing parallel items from the March Current Population Survey (CPS), which is developed and fielded jointly by Census and BL S and used for offic ial poverty statistics, and from the National L ongitudinal Study of Youth (NL SY) fielded by BLS.
2. Indicate how, by

whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. The RGEES pilot test will measure unit response rates and enable comparisons to earnings data collected through other survey s and in administrative records. The pilot study results will be used to compare median earnings collected through the survey to median earnings for graduates from comparable programs based on a match to the Social Security Administration as part of the 2012 gainful employ ment informational rates. The results of the pilot will als o be compared to earnings estimates in the CPS and the ACS. If needed based on the pilot test results and public comment, the RGEES will be revised prior to posting on ED’s website on December 15, 2015. The National Student Loan Data S ys tem (NSLDS) is th e sample frame for this study . A total of 3,400 sample members will be chosen from among the universe of gainful employ ment program and for

- profit institution graduates who completed their program between July

1, 2009 and June 30, 2011. 2 To facilitate comp arisons to the 2012 gainful employ ment informational rates, respondents will be selected in four categories from the Classification of Instructional Programs (CI P) based on the ty pe of program they completed: cosmetology

and related personal grooming servi ces (12.04); somatic body work and related therapeutic services (51.35); practical nursing, vocational nursing, and nursing assistants (51.39); and all others. 3 Overall unit response rates for the RGEES are expected to be at least 50 percent of an identifi ed cohort and, in keeping with the draft standards for its administration, a nonresponse bias anal ys is (NRBA) will be required when unit response rates are less than 80 percent. At the completion of the pilot study , the NRBA will compare respondents and no n - respondents within the program areas targeted. Demographic and other

2 For the pilot study, graduates from programs in Puerto Rico will be excluded since a Spanish translation of the survey is not yet available. 3 Categories include all six digit CIP code programs within the referenced four digit CIP code.3

OMB Number: 1845

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- XXXX (if applicable) characteristics of both the respondents and non

- respondents needed for the NRBA will be obtained from the NSLDS from which the sample will have been selected. Appendix 2 contains the RGEES questionnaire and Appendix 3 contains respondent contact materials. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology , e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. The pilot test will be conduc ted using a mailed pencil and paper instrument. A fully automated survey

control sy stem will monitor the survey instrument from initial mailing. High

- volume mail preparation hardware and software will automate the mailing process, and hard cop y questionnai res returned for processing will be scanned in and managed by the automated receipt control and document management sy stem. Once received, hard copy survey s will be receipted and scanned for data entry , then destro ye d. 4. Describe efforts to identify d uplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. The purpose of this request for clearance is to pilot test a survey of graduates that will be used by postsecondary

programs subject to the gainful employ ment regulation as part of an appeal of the earnings estimate used in the debt

- to

- earnings ratio. This is a new option provided to programs as part of the final regulations published in October 2014. T his is the first time that these items have been tested for this purpose. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not

- for

- profit enterprise that is independently owned and operated and is not dominant in its field; or ( 3) a small government jurisdiction, which is a government of a city , count y, town, township, school district, or special district with a population of less than 50,000. This information collection does not involve small businesses or other small entities. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. This information collection is for the pilot of the survey that is included in the regulations at 668.406, D/E rates alternate earnings appeal. If this pilot is not performed, institutions will not be able to use the regulatory options available to them under the debt to earnings rate appeal.4

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable)
7. Explain any

special circumstances that would cause an information collection to be conducted in a manner:

 requiring respondents to report information to the agency more often than quarterl y;
 requiring respondents to prepare a written response to a collection of i nformation in fewer than 30 day s after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, grant

- in

- aid, or tax recor ds for more than three ye ars;
 in connection with a statistical survey , that is not designed to produce valid and reliable results than can be generalized to the universe of study ;
 requiring the use of a statistical data classification that has not been rev iewed and approved b y OMB;

 that includes a pledge of confidentiality that is not supported by

authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnece ssaril y i mpedes sharing of data with other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to prot ect the information’s confidentiality to the extent permitted by law. None of the special circumstances listed in the instructions for completing the supporting statement apply

to the RGEES.
8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken b y the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability

of data, frequency

o f collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 y ears

– even if the collection of information activity

is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstance s should be explained. ED is requesting and will comments provided by the public during the 60

- day and 30

- day public comment periods. This is the request for the 60

- day public comment period. The initial survey

and plans for its testing were developed with input from a Technical Review Panel (TRP) that met on December 2, 2014. The results of the first round of5

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) cognitive testing, which was conducted in January and February 2015, were shared with a second panel of earnings experts convened b y the Nationa l Institute of Statistical Sciences (NI SS) on February

27, 2015. The most significant recommendation from the first round of testing was to combine all income questions into a single multi

- part question in order to help respondents correctly

distinguish so urces of income without double counting. Neither the time burden imposed by

the survey

nor the sensitivity

of the items was reported as a concern by participants. The most significant recommendation from the NISS panel was to revamp the questions to help r espondents understand the need to report income from **all** sources and to help them recall their earnings information from two y ears prior to data collection. To improve recall, the revised survey asked respondents to focus first on the job they held the longest (per approaches tested previousl y for CPS), and the n on all other jobs. This approach was designed to help respondents think about their actual emplo ym ent situation in 2013, with the goal to elicit total earnings and to not count earnings for the longest job separately . A second round of cognitive testing, conducted in April 2015, found that respondents had a good understanding of the intent of the questions and that double counting was minimized in this new format. A report from both rounds of cognitive testing is included in Appendix 4

. **RGEES Technical R eview Panel Members (December 2, 2014** 
**- Washington, DC)**  Geri Anderson Special Assistant to the President for External Affairs Aims Community

College 5401 West 20th Street Greeley , CO 80632 Angela Bell Senior Executive Director of Research and Policy Anal ys is University

S ys tem of Georgia 270 Washington Street SW Atlanta, GA 30334 Jennifer Blum Senior Vice Present, External Relations & Public Policy Laureate Education, Incorporated 1500 K Street NW, Suite 250 Washington, DC 20005 Kathy Booth Senior Research Associate WestEd 300 L akeside Drive, 25th Floor Oakland, CA 94612 Patrick Crane Project Manager West Virginia Community & Technical College S ys tem 1018 Kanawha Boulevard East, Suite 700 Charleston, WV 25301 Mark DeFusco Senior Research Associate University

of Southern California Rossier School of Education Waite Phillips Hall WPH 7 01B Los Angeles, CA 90089

- 4037 Christine Fuglestad Director of Government Affairs Capella Universit y 225 South 6th Street, 9th Floor 5019 Wentworth Avenue Minneapolis, MN 55419 Alfred Gottschalck Chief, Labor Force Statistics Branch US Census Bureau 4600 Silver Hill Road Washington, DC 202336

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) KC Greaney Director, Office of Institutional Research Santa Rosa Junior College 680 Sonoma Mountain Parkway Richard Call Bldg., Annex Petaluma, CA 94954 Stephen Haworth Senior Manager, Reporting & Po licy Research Devry Education Group 3005 Highland Parkway Downers Grove, IL 60515 G. Scott Jenkins Vice Provost for Academic Affairs and Undergraduate Programs North Carolina A&T State Universit y 1601 East Market Street Dowdy Building 318 Greensboro, N C 27411 Anthony Jones Graduate Faculty Appalachian State University 151 College Street, Suite 217

- B Boone, NC 28608 John Kolotos Policy Anal ys t U.S. Department of Education 1990 K Street NW Washington, DC 20202 Tod Massa Director, Policy

Research and Data Warehousing State Council of Higher Education for Virginia 101 North 14th Street Richmond, VA 23219 Heather McKay Director, Education and Employ ment Research Center Rutgers University 94 Rockafeller Road Piscataway , NJ 08854

- 8054 Charles Nels on Assistant Division Chief, Economic Characteristics Census Bureau 4600 Silver Hill Road Washington, DC 20233 Kent Phillipe (unable to attend) Associate Vice President, Research & Student Success American Association of Community Colleges One Dupont Circle NW Suite 410 Washington, DC 20036 Anne Polivka Supervisory

Research Economist, Employ ment Research Chief Bureau of Labor Statistics 2 Massachusetts Avenue NE, Suite 4945 Washington, DC 20212 Casey Sacks Manager Colorado Community

College S ys te m 9101 East L owry

Boulevard Denver, CO 80230 Rajat Shah Senior Vice President, Student Financial Services Lincoln Technical Institute 200 Executive Drive, Suite 340 West Orange, NJ 7052 Christine Tracy Director of Research Association for Private Sector Colleges and Universities 1100 Connecticut Avenue NW Suite 900 Washington, DC 20036 Christina Whitfield Vice Chancellor Kentuck y Community

& Technical College Sy stem 300 North Main Street Versailles, KY 403837

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) Paul Umbach Professor, Higher Edu cation and Educational Evaluation and Policy

Analy sis Department of Leadership, Policy , and Adult and Higher Education North Carolina State University 300 Poe Hall, Box 7801 Raleigh, NC 27695

**National Institute of Statistical Sciences Panel Members (February 27, 2014** 

**– Washingtond DC)**  Katherine Abraham Professor of Economics and Survey Methodology University

of Maryland 1218 L eFrak Hall College Park, MD 20742 Michael Larsen Associate Professor Georg e Washington University Rome Hall 801 22nd Street NW Washington, DC 20052 Emilda Rivers Program Director, Human Resources Statistics National Center for Science and Engineering Statistics National Science Foundation 4201 Wilson Boulevard Arlington, VA 22230 Joy Edington ESSI N Research Anal ys t/Statistician National Institute of Statistical Sciences 1776 Ey e Street NW Washington DC, 20006 Martin Frankel Professor of Statistics The City Universit y of New York Baruch College One Bernard Baruch Way (55 Lexington Avenue, at 24th Street) New York, NY 10010 Clyde Tucker Principal Researcher, Education Program American Institutes for Research 1000 Thomas Jefferson Street NW Washington, DC 20007

9. Explain any

decision to provide an y pa ym ent or gift to respondents, other than remuneration of contractors or grantees with meaningful justification

. Survey respondents will be offered a $25 incentive for returning a completed survey during the pilot test, and will be able to choose between receiving the incentive pay ment either b y check, which t ypically takes up to 4 weeks to be delivered, or b y PayPal , sent immediately

to an email address provided in the survey , once receipt of the survey is confirmed. Choice of payment method will be included at the end of the survey where participants will be asked to provide an email address if they choose PayPal. Use of incentives for the pilot survey is recommended for several reasons. First, as overall response rates in survey research are declining, achieving the desired 60 percent response rate will be especiall y challenging because of the sensitive nature of the earnings questions. Second, the pilot survey has an abbreviated data collection timeframe in order to release the final survey in time to be available in spring when institutions will be able to begin appealing FSA’s debt to earnings calculation. Final ly , the pilot is only a paper and pencil survey , which tends to have low response rates without multi

- mode follow

- up options. Respondents will have the option to decline the incentive if desired.8

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) 10. Describe an y assurance of confidentiality provided to r espondents and the basis for the assurance in statute, regulation, or agency policy . If personally

identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 4 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. Respondents will be informe d that their responses to this data collection will be used only for statistical purposes and that the results of this study will summarize findings across the sample and will not associate responses with a specific individual. The name of the respondent w ill not be scanned or maintained. Additionally , respondents will be informed that no identifying information will be shared outside the study team (Privacy Act of 1974 5 U.S.C. § 552(a), 2009; Family Educational and Privacy Act of 1974, 20 U.S.C. § 1232(g ), 2009). 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y th e agency considers the questions necessary , the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and an y steps to be taken to obtain their consent. The RGEES pilot test is a volunt ary survey, and no persons are required to respond to it. In addition, respondents may decline to answer any

question in the survey . Respondents will be informed of the voluntary nature of the survey

in the cover letter that accompanies the questionnaire, as well as on the actual questionnaire. At the same time, survey items verifying personal identity and asking about earnings may be considered sensitive by some respondents. Thus all of the four survey items on the RGEES may be considered sensitive. The first question asking the respondent to verify his or her identity

is needed because earnings are being collected from a defined cohort of graduates negotiated between ED and the program. The mean and median earnings measures that will be submitted to ED a s part of the appeals process must be based on actual earnings from the universe of cohort members responding to the survey

. The next three questions ask about sources (from an employ er, from self

- employ ment, other) and amounts of earnings during the ref erence ye ar. These questions are drawn

4 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A

- 108

– Privacy Act Implementation

– Guidelines and Responsibilities, OMB Circular A

- 130 Appendix I

– Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M

- 03

- 22

– OMB Guidance for Implementing the Privacy Provisions of the E

- Government Act of 2002, OMB M

- 06

- 15

– Sa feguarding Personally Identifiable Information, OM : 6

- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)9

OMB Number: 1845

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- XXXX (if applicable) from parallel items from the March CPS, which is developed and fielded jointly by Census and BLS and used for official povert y statistics, and from NL SY fielded by BLS as described in Appendix 1. These items are neede d in order to calculate the mean and median of total earnings (and the number of true zeros) for the cohort during the reference period to submit to ED as part of the alternative earnings appeal process.
12. Provide estimates of the hour burden of the col lection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for

- profit, private sector

– not

- for

- profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be inclu ded in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on re spondents is expected to vary widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual b usiness practices.

 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categorie s. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14. NCES estimates a response rate of 60% and about 5 minutes per respondent to com plete the pilot test survey

. **Estimate respondent burden for pilot study Activity**  **Number of sampled**  **respondents Number of** 

**responses Minutes per** 

**respondent Maximum** 

**total burden hours**  Pilot testing 3,400 2,040 5 170 **Study Total 3,400**  **2,040 170** 

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)10

OMB Number: 1845

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- XXXX (if applicable)

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

- up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start

- up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaini ng record storage facilities.

 If cost estimates are expected to vary widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60

- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.

 Generally , estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirement s not associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requeste d : There are also no recordkeeping requirements and no costs to respondents bey ond the time to participate

. 14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. The cost to the federal government for developing and cognitive and pilot testing the survey is $555,570, which includes contractor staff time, incentives, and project materials. 15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result from re

- estimating burden and/or from economic phenomenon outside of an agency ’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materiall y changes a11

OMB Number: 1845

- NEW Revised: 5 / 11 / 2015 RIN Number: XXXX

- XXXX (if applicable) collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty

pe of collection (new, revision, extension, reinstatement with ch ange, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)

. This is a request for a new information collection. This collection is necessary to meet regulatory

requirements in 34 CFR 668.406. This new collection is a program change due to agency

discretion. ED is requesting an increase in170 burden hours to 2,040individuals.
16. For collections of information whose results will be published, outline plans for tabulation and publication. Addr ess any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. The pilot study will begin in earl y September and end in late October 2015. All RGEES development activities to anal yz e the data and finalize the survey need to be completed by the middle of November. If needed based on the pilot test results and public comment, the RGEES will be revised prior to posting on ED’s website b y December 15, 2015.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate. The OMB authorizat ion number and expiration date will be display ed on the survey form.
18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. There are no exceptions to the certification statement.