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OMB Number: 1845-NEW Revised: 5/11/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK 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 copy of the 

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

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

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

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

The National Center for Education Statistics (NCES) of the U.S. Department of 

Education (ED) is required by regulation to develop an earnings survey to support gainful 

employment 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 conduct 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 Employment and Earnings Survey (RGEES). The 

data collection for this study is being carried out under contract to NCES by RTI

International (contract # ED-IES-13-C-0070).

Postsecondary programs subject to the gainful employment 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 by 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 appeal 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 earnings 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 for public comment in a separate announcement.

 

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OMB Number: 1845-NEW Revised: 5/11/2015

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In preparation for this submission, NCES reviewed existing person-level surveys 

conducted regularly by the United States Census Bureau (Census) and the Bureau of 

Labor Statistics (BLS) for data collection approaches 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 Statistics Branch at Census). Anne 

Polivka, Chief of the Statistics Employment Research Division, represented BLS. In 

addition, Katharine Abraham, former director of BLS and a recent member of the 

President’s Council of Economic Advisors, was instrumental in revisions 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 BLS and used for official poverty statistics, 

and from the National Longitudinal Study of Youth (NLSY) 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 surveys 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 employment informational rates. The 

results of the pilot will also 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 System (NSLDS) is the sample frame for this study. A 

total of 3,400 sample members will be chosen from among the universe of gainful 

employment program and for-profit institution graduates who completed their program 

between July 1, 2009 and June 30, 2011.2To facilitate comparisons to the 2012 gainful 

employment informational rates, respondents will be selected in four categories from the 

Classification of Instructional Programs (CIP) based on the type of program they

completed: cosmetology and related personal grooming services (12.04); somatic 

bodywork 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 

identified cohort and, in keeping with the draft standards for its administration, a 

nonresponse bias analysis (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 

non-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.
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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 any consideration given to using 

technology to reduce burden.

The pilot test will be conducted using a mailed pencil and paper instrument. A fully

automated survey control system will monitor the survey instrument from initial mailing. 

High-volume mail preparation hardware and software will automate the mailing process, 

and hard copy questionnaires returned for processing will be scanned in and managed by

the automated receipt control and document management system. Once received, hard 

copy surveys will be receipted and scanned for data entry, then destroyed. 

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

already available cannot be used or modified for use for the purposes described in Item 2 above.

The 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 employment 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. This 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 entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently

owned and operated and is not dominant in its field; or (3) a small government jurisdiction, 

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

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 frequently, as well as any 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.
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7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

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

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

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

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

results than can be generalized to the universe of study;

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

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established in 

statute or regulation, that is not supported by disclosure and data security policies that are 

consistent with the pledge, or that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

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

information unless the agency can demonstrate that it has instituted procedures to protect 

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

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 by 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 by the agency in response to these comments. Specifically address 

comments received on cost and hour burden.

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

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

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

reported.

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

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

information activity is the same as in prior periods. There may be circumstances that may

preclude consultation in a specific situation. These circumstances should be explained.

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 of 
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OMB Number: 1845-NEW Revised: 5/11/2015

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cognitive testing, which was conducted in January and February 2015, were shared with a 

second panel of earnings experts convened by the National Institute of Statistical Sciences 

(NISS) 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 sources 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 respondents understand the need to report income from all sources and 

to help them recall their earnings information from two years 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 previously for CPS), and then on all other jobs. This approach 

was designed to help respondents think about their actual employment 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 Review 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 Analysis

University System 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 Lakeside Drive, 25th Floor

Oakland, CA 94612

Patrick Crane

Project Manager

West Virginia Community & Technical 

College System

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 701B 

Los Angeles, CA 90089-4037

Christine Fuglestad

Director of Government Affairs

Capella University

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 20233
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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 & Policy

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 University

1601 East Market Street

Dowdy Building 318 

Greensboro, NC 27411

Anthony Jones

Graduate Faculty

Appalachian State University

151 College Street, Suite 217-B

Boone, NC 28608

John Kolotos

Policy Analyst

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 Employment 

Research Center

Rutgers University

94 Rockafeller Road

Piscataway, NJ 08854-8054

Charles Nelson

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, 

Employment Research Chief

Bureau of Labor Statistics

2 Massachusetts Avenue NE, Suite 4945

Washington, DC 20212

Casey Sacks

Manager

Colorado Community College System

9101 East Lowry 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

Kentucky Community & Technical College 

System

300 North Main Street

Versailles, KY 40383
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Paul Umbach

Professor, Higher Education and Educational 

Evaluation and Policy Analysis

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 LeFrak Hall 

College Park, MD 20742

Michael Larsen

Associate Professor

George 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

ESSIN Research Analyst/Statistician 

National Institute of Statistical 

Sciences 

1776 Eye Street NW

Washington DC, 20006

Martin Frankel

Professor of Statistics

The City University 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 any payment 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 payment 

either by check, which typically takes up to 4 weeks to be delivered, or by 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 especially 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. Finally, 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.
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10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.4If the collection is subject to the

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

Respondents will be informed 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 will 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 any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered private. 

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

The RGEES pilot test is a voluntary 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 

as 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 employer, from self-employment, 

other) and amounts of earnings during the reference year. These questions are drawn 

 

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

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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from parallel items from the March CPS, which is developed and fielded jointly by

Census and BLS and used for official poverty statistics, and from NLSY fielded by BLS 

as described in Appendix 1. These items are needed 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 collection of information. The statement should:

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

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

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

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

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. Unless directed to do 

so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary widely 

because of differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, estimates should 

not include burden hours for customary and usual business practices.

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

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

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

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

NCES estimates a response rate of 60% and about 5 minutes per respondent to complete 

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

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into account 

costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

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

equipment; and acquiring and maintaining record storage facilities.

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

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

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions 

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

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and 

usual business or private practices. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There are also no recordkeeping requirements and no costs to respondents beyond 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 any program changes or adjustments. Generally, adjustments in 

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

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

reporting universe). Program changes result from a deliberate action that materially changes a 
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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 type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

This is a 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. Address any complex analytical techniques that will be used. Provide the time 

schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

The pilot study will begin in early September and end in late October 2015. All RGEES 

development activities to analyze 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 by 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 authorization number and expiration date will be displayed 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.