Implementation of Title I/II Program 

Initiatives

Supporting Statement for Paperwork Reduction 

Act Submission

PART A: Justification 

Contract ED-IES-11-C-0063

September 2013

Prepared for:

Institute of Education Sciences

U.S. Department of Education

Prepared by:

Westat

Mathematica Policy Research

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Table of Contents

Introduction.............................................................................................................. 1

Overview of the Study............................................................................................... 1

A.1. Explanation of Circumstances That Make Collection of Data 

Necessary .............................................................................................. 3

A.2. How the Information Will Be Collected, by Whom, and For What 

Purpose ................................................................................................. 4

A.2.1. New Data Collections........................................................................... 5

A.2.2. Extant Data Sources............................................................................. 6

A.3. Use of Improved Information Technology to Reduce Burden................... 7

A.4 Efforts to Identify and Avoid Duplication ................................................ 8

A.5. Efforts to Minimize Burden on Small Business or Other Entities .............. 8

A.6. Consequences of Less-Frequent Data Collection...................................... 8

A.7. Special Circumstances Requiring Collection of Information in a 

Manner Inconsistent with Section 1320.5(d)(2) of the Code of 

Federal Regulations ............................................................................... 8

A.8. Federal Register Comments and Persons Consulted Outside the 

Agency .................................................................................................. 8

A.9. Payments to Respondents...................................................................... 9

A.10. Assurance of Confidentiality................................................................... 9

A.11. Questions of a Sensitive Nature.............................................................10

A.12. Estimates of Respondent Burden...........................................................11

A.13. Estimates of the Cost Burden to Respondents........................................12

A.14. Estimates of Annualized Government Costs...........................................12

A.15. Changes in Hour Burden........................................................................12

A.16. Time Schedule, Publication, and Analysis Plan .......................................12

A.16.1. State, District, and School Level Implementation........................... 13

A.16.2. Cross-Level Analysis........................................................................ 14

A.16.3. Student Achievement Trends ......................................................... 15

A.17. Display of Expiration Date for OMB Approval ........................................16

A.18. Exceptions to Certification Statement....................................................16

References .............................................................................................................17

Appendix A State Survey and Extant Data Form ...................................................... A-1

Appendix B District Survey...................................................................................... B-1

Appendix C Principal Survey ....................................................................................C-1

Appendix D Teacher Survey .................................................................................... D-1

Appendix E Teacher Roster......................................................................................E-1

Appendix F Notification Letters................................................................................F-1

Appendix G Study Brochure.................................................................................... G-1
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Tables

A - 1. Research questions and data sources....................................................... 5

A - 2. Estimates of respondent burden ..............................................................12
1

Part A. Justification

This package is the first of two for the Implementation of Title I/II Program Initiatives study. This package 

requests approval for an initial round of recruitment and data collection that will include surveys of all 

states, nationally representative samples of school districts and schools, and a nationally representative 

sample of Kindergarten through 12th grade core academic and special education teachers. We 

anticipate that the state education agency (SEA), school district, principal, and teacher surveys will begin 

in January 2014. The second package will request approval for the follow-up survey, which will survey 

the same states, districts, and schools as well as a new nationally representative sample of teachers 

within the sampled schools.

Introduction

Title I is one of the U.S. Department of Education’s (ED) largest elementary and secondary education 

programs. Historically, Title I provides financial assistance to schools and districts with a high percentage 

of students from low-income families to help these students increase achievement. Title I also includes 

requirements that states hold schools and districts accountable for improvements in student 

achievement. During the 2009-2010 school year, more than 56,000 public schools used Title I funds, and 

the program served 21 million children (U.S. Department of Education, 2012a). Title II provides funds to 

increase academic achievement by improving teacher and principal quality including educator 

preparation and professional development, as well as providing funds for class size reduction. An 

estimated 95 percent of districts nationally received Title II, Part A funding for the 2011-12 school year 

(U.S. Department of Education, 2012b).

The last National Assessment of the Title I program concluded in 2006. Since that time, there have been

changes in Title I provisions, such as allowing states to incorporate proficiency improvement (alongside 

proficiency levels) into school accountability measures and providing more resources to the lowest 

performing schools through the expansion of eligibility and funding for School Improvement Grants 

(SIG). Title II guidance allows more flexibility for certain teachers (e.g., special education teachers) to 

meet the standards to become highly qualified teachers (HQT). 

The most recent change related to Title I and Title II was the introduction of the Elementary and 

Secondary Education Act (ESEA) Flexibility requests in 2011, allowing states to waive a number of 

provisions in exchange for a commitment to key reform principles. The Title I/II study will provide policy 

makers with detailed information on how these initiatives are playing out in states, districts, schools, 

and classrooms.

Overview of the Study

The study of the Implementation of Title I/II Program Initiatives is commissioned by the Institute of 

Education Sciences (IES), ED’s independent research and evaluation arm. The Title I/II study will examine 

the implementation of policies promoted through ESEA at the state, district, school, and classroom

levels. Through surveys at each level and selected extant data and documents, the study will provide 
2

information on activities in four core areas: state content standards, assessments, school accountability, 

and teacher and principal evaluation.

The study will reflect changes in Title I and Title II provisions since the last National Assessment of the 

Title I program concluded in 2006 (including ESEA Flexibility provided to states with approved requests). 

In addition, this study will supplement findings from ED’s annual survey of a nationally representative 

sample of districts on their uses of Title II, Part A funds. This study will provide more detail on districtimplemented workforce development policies and practices for educators as well as teachers’ and 

principals’ access to and receipt of professional development. 

State content standards

State content standards have been a foundational element of ESEA since the 1994 reauthorization of the 

Act, which required states to establish statewide standards in reading and mathematics in the 3 through 

5, 6 through 8, and high school grade ranges and implement statewide accountability systems for 

evaluating school-level performance. The No Child Left Behind Act of 2001 (NCLB), the subsequent 

reauthorization of ESEA, extended and strengthened these concepts, incorporating science alongside 

reading and math, and establishing more prescriptive rules for state accountability systems. More 

recently, states approved for ESEA Flexibility have agreed to adopt especially rigorous standards; over 40 

states have adopted the Common Core State Standards (CCSS). 

Assessments

The 1994 reauthorization of ESEA required states to administer annual academic assessments aligned to 

content standards in reading and mathematics in at least one elementary grade, one middle grade, and 

one high-school grade. In 2001, NCLB extended this requirement from three grades to seven (grades 3-8 

and at least once in high school) and added a requirement for science assessments in each of the 3-5, 6-

8, and high school grade ranges. 

These assessments are meant to provide information on whether students have acquired the knowledge 

and skills identified by the standards and, if not, the areas where students fall short and may require 

additional instruction and assistance. Annual assessment data are also used to hold schools and districts, 

and increasingly teachers, accountable for student performance. The content and rigor of these 

assessments vary across states.

School accountability 

NCLB standardized state accountability policies by requiring states to establish “adequate yearly 

progress” (AYP) goals and objectives for student proficiency on the mandated assessments, with targets 

rising over time so that by 2014, all students would be proficient. Schools and school districts are held 

accountable for achieving rates of student proficiency in reading and mathematics that meet the annual 

objectives, as well as for the proficiency rates of specific subgroups of students. Schools that failed to 

meet AYP for either all students or a subgroup of students over successive years were subject to an 

increasingly aggressive set of interventions spelled out in the law, beginning with parental choice and 

culminating with school closing or state takeover.
3

The federal government has adjusted accountability requirements since the last National Assessment. 

The Growth Model Pilot Project, initiated in 2005, permitted nine states to use accountability measures 

that incorporate proficiency improvement (rather than only proficiency levels) under a pilot in 2007-08. 

When the approach was written into regulations in 2008, 15 states participated. The ESEA Flexibility 

regulations introduced in 2011 allow states to develop more flexible systems of school accountability 

that incorporate measures of the achievement growth of individual students, broaden achievement 

measures beyond mathematics and reading, and include other student outcomes such as graduation 

rates. In addition, recent policy changes have led to more intensive focus on the lowest-performing 

schools and differentiated support for schools depending on their performance levels

Teacher and principal evaluation

Improving and supporting the effectiveness of teachers and school leaders is a key part of any strategy 

for improving student achievement and college and career readiness. Research has shown that teachers 

(e.g., Rowan, Correnti, & Miller, 2002; Rockoff, 2004; Rivkin, Hanushek, & Kain, 2005) and school 

administrators (e.g., Witziers, Bosker, & Kruger, 2003) have measurable effects on student achievement.

Title I and Title II incorporate a number of requirements and incentives for states and districts to 

implement policies that improve certification, support educators during all phases of their careers, hold 

them accountable for contributing to student achievement, and ensure their equitable distribution—all

based on the premise that improvement in student achievement requires improving educator quality. 

However, there has been substantial development in the national discourse about teacher quality since 

the passage of the NCLB and the initiation of the last National Assessment of Title I.

Most importantly, thinking about educator quality has shifted away from educator inputs (e.g., degrees 

and certifications) toward educator performance, defined in terms of practice and especially in terms of 

contribution to growth in student achievement. This shift has been facilitated by the improvements in 

the assessment of educator practice (Porter, Youngs, & Odden, 2001; Milanowski, Heneman & Kimball, 

2011) and in “value-added” methods to measure school and teacher contributions to student 

achievement (Meyer, 1997; Harris, 2009; Glazerman et al., 2010). 

A.1. Explanation of Circumstances That Make Collection of Data Necessary

The purpose of this new data collection is to provide information on the progress being made on the 

core policies promoted by Title I and Title II, and the recent granting of ESEA Flexibility requests to 

states. Historically, Congress has mandated a national study of the Title I program. Title I, Part E, Section 

1501 of the ESEA, as amended, mandated the most recent National Assessment of the implementation 

and impact of Title I, which concluded in 2006 (see 

http://www2.ed.gov/policy/elsec/leg/esea02/pg12.html). This Title I study is planned in anticipation of 

the next reauthorization of ESEA. The Title II study is authorized under Part F, Section 9601 of ESEA, 

which permits program funds to be used to evaluate activities authorized under the act (see 

http://www2.ed.gov/policy/elsec/leg/esea02/pg113.html). The timing of the study’s data collection is 

critical to provide information prior to the reauthorization of ESEA, and provide policy makers with 

information on the implementation of ESEA Flexibility requests.
4

Although there are research studies that cover similar topics of recent federal education policy, this 

proposed Title I/II study is set apart by the breadth of research questions and the depth of responses 

from all SEAs and three levels (nationally representative samples of districts, principals, and core 

academic and special education teachers). The research questions for the Title I/II study are as follows:

1. What content standards and high school graduation requirements are states adopting, and what 

materials and resources do states, districts, and schools provide to help teachers implement the 

state content standards?

2. What assessments do states and districts use (in terms of assessment format and coverage of grade 

levels and content areas), and what materials and resources do states, districts, and schools provide 

to support the implementation of assessments and use of assessment data?

3. How has student achievement changed over time?

4. What elements are included in states’ accountability systems? How do states and districts identify 

and reward their highest-performing schools, identify and support their lowest-performing schools, 

and offer differentiated support for schools that are neither highest-performing nor lowestperforming?

5. How do states and districts evaluate teacher and principal effectiveness and assess equitable 

distribution of teachers and principals, and what supports do states, districts, and schools provide to 

improve teacher and principal effectiveness? 

A.2. How the Information Will Be Collected, by Whom, and For What 

Purpose

In order to address the research questions described above, this study will rely on a new set of surveys

and information collected from existing sources, for which there are no additional respondents or 

burden. See Table A - 1 for the linkages between the research questions and the sources of information 

to answer the questions.
5

Table A - 1. Research questions and data sources

Research Question Data Source(s)

1. What content standards and high school graduation 

requirements are states adopting, and what 

materials and resources do states, districts, and 

schools provide to help teachers implement the 

state content standards?

State surveys

District surveys

Principal surveys

Teacher surveys

2. What assessments do states and districts use (in 

terms of assessment format and coverage of grade 

levels and content areas), and what materials and 

resources do states, districts, and schools provide to 

support the implementation of assessments and use 

of assessment data?

State surveys

District surveys

Principal surveys

Teacher surveys

3. How has student achievement changed over time? NAEP (National Assessment of

Educational Progress) data

EDFacts data

4. What elements are included in states’ accountability 

systems? How do states and districts identify and 

reward their highest-performing schools, identify 

and support their lowest-performing schools, and 

offer differentiated support for schools that are 

neither highest-performing nor lowest-performing?

State surveys

District surveys

Principal surveys

Teacher surveys

State documents

5. How do states and districts evaluate teacher and 

principal effectiveness and assess equitable 

distribution of teachers and principals, and what 

supports do states, districts, and schools provide to 

improve teacher and principal effectiveness? 

State surveys

District surveys

Principal surveys

Teacher surveys

State documents

A.2.1. New Data Collections

There currently is no uniform source of current, detailed information on the study’s core areas. We will 

administer surveys to obtain this information. Each survey is described below.

State survey. The state survey, administered on paper or electronic PDF form, will focus on state 

policies, and in particular, the adoption of state content standards, assessments, accountability and lowperforming schools, teacher and principal evaluation, and ESEA Flexibility provisions. The survey will be 

sent to the chief school officer in each of the 50 states and the District of Columbia beginning in January 

2014, with the expectation that different sections of the survey may be filled out by different staff in the 
6

SEA, as determined by their particular expertise. The state survey contains a different set of questions in 

Section 3 (school accountability) for states that have an approved ESEA Flexibilty request and states 

without ESEA Flexibility.1 The state survey with the two versions for Section 3 is in Appendix A.

District survey. This web-based survey will focus on the implementation of state policies, adoption of 

district policies such as supplemental district content standards and assessments, and supports provided 

to schools. The survey will be administered to superintendents or their designees from a nationally 

representative sample of 570 districts beginning in January 2014. The district survey is in Appendix B.

Principal survey. This web-based survey will focus on the implementation of state and district policies 

within schools, the usefulness of supports received from the state and district, and supports provided to 

teachers. These surveys will also address how principals’ performance is evaluated, and how principals 

evaluate teachers’ performance. The survey will be administered to principals from a nationally 

representative sample of 1,300 schools (nested within the sampled districts) beginning in January 2014. 

The principal survey is in Appendix C

Teacher survey. This web-based survey will focus on the implementation of state and district policies in 

classrooms, and the usefulness of supports received from the state, district, and school. These surveys 

will also address how teachers’ performance is evaluated. The survey will be administered to a 

nationally representative sample of 9,100 core academic and special education teachers from the 

sampled schools beginning in January 2014.

2

In limiting the sample to these types of teachers, the 

sample will include teachers most likely to be affected by the various initiatives and programs promoted 

by Title I and the ESEA Flexibility waivers. The teacher survey is in Appendix D.

Teacher roster. The principals of sampled schools will be asked to provide comprehensive lists of core 

academic and special education teachers in their schools, which will be used as the sampling frame for 

the teacher sample. The principal or his/her designee will be asked to verify their school’s current grade 

spans and list all current teachers whose subject most often taught is reading/English/language arts, 

mathematics, science, social studies, general elementary, or special education. For each of these 

teachers, the school will identify the subject most often taught, the main grade for the subject most 

often taught, and whether the teacher teaches any class whose students are tested for accountability 

requirements under ESEA. The collection of teacher roster information will begin in January 2014. A 

mockup of the web-based teacher roster is in Appendix E.

A.2.2. Extant Data Sources

Extant data. The data for the student achievement analyses will come from the National Assessment of 

Educational Progress (NAEP) and EDFacts. NAEP is a nationally representative assessment of students in 

mathematics, reading, and other subjects that provides a common measure of achievement across 

states. EDFacts data are consolidated from annual state reports and include school-level performance 

on state assessments and adequate yearly progress (AYP) status for all schools in the state. The 

outcomes of interest for this study are state-level standardized test scores (using NAEP and state 

 

1 For the purposes of the baseline survey, we consider ESEA Flexibility states as those states with an approved ESEA Flexibility request and are 

expected to implement the Flexibility policies during the 2013-14 school year.

2 Core academic and special education teachers are those teachers whose subject most often taught is reading/English/language arts, 

mathematics, science, social studies, general elementary, or special education.
7

assessments). The analyses will focus on state-level trends and cross-state trends in student proficiency 

levels over time.

ED also collects data from states on elements of state teacher preparation programs and state 

requirements for initial teacher certification or licensure, including information about teacher 

preparation and certification programs and policies, as well as the number of people entering and 

completing programs. The current data provide information on changes in state policies, such as 

increases in the rigor of teacher preparation or reductions in the barriers to alternative certification 

routes, from 2008 through 2010. (Information through 2012 is expected to be available in 2013.) 

State documents. State documents in the public domain will be collected and reviewed, particularly to 

learn the details of state accountability policies and teacher evaluation requirements. For example, 

documents may include state website information on policies. The study team will complete an extant 

data form (see Appendix A) for each state, then ask SEA staff to verify that the information in the form is 

correct. 

A.3. Use of Improved Information Technology to Reduce Burden

The data collection plan is designed to obtain information in an efficient way that minimizes respondent 

burden. When feasible, we will gather information from existing data sources. The state survey will be 

divided into modules which will allow the appropriate staff with expertise in each area to respond

separately. This approach will reduce burden for respondents as (a) each individual will have fewer 

questions to answer and (b) respondents will be asked questions concerning topics in which they are 

well versed and answers should be readily available. Each state will be given access to a secure 

SharePoint site to facilitate access for multiple respondents to the survey and to allow respondents to 

forward any documents they feel would help us better understand their state policies.

Web-based surveys will be the primary mode of data collection for the district, school and teacher 

surveys. We have found web-based surveys to be a preferred method for survey completion among 

many respondents. Moreover, web-based administration decreases the cost for postage, coding, keying 

and cleaning of the survey data. Burden will be reduced with the use of skip patterns and prefilled 

information based on responses to previous items when appropriate. The web-based survey will allow 

respondents to complete the survey at a location and time of their choice, and built-in edits will reduce 

response errors. At the district level, the web-based surveys will facilitate the completion of the surveys 

by multiple respondents, so that the most appropriate individual will be able to access and provide the 

data in their area of expertise.

For respondents that choose not to use the web-based survey, we will offer the option of completion of 

an electronic version of the survey or a paper-and-pencil instrument. A phone survey option will be 

offered to respondents as part of the nonresponse follow-up effort.

Principals can also use the web to enter data for the teacher rosters. Online edits in the web roster will 

ensure that all data items required for teacher sampling are entered. We will also make available at the 

school’s request an Excel template should the school prefer to enter teacher information in Excel. Roster 

output from the school’s database, either electronically or on hardcopy, also will be acceptable. We will 

work with the principal or his/her designee to be sure all fields required for the teacher sampling are 

captured.
8

A.4. Efforts to Identify and Avoid Duplication

To avoid duplication, we will use extant state data when available rather than ask extensive questions of 

the state respondents.

A.5. Efforts to Minimize Burden on Small Business or Other Entities

No small businesses will be involved as respondents. Every effort will be made to minimize the burden 

on respondents.

A.6. Consequences of Less-Frequent Data Collection

Title I has not been studied with a nationally representative sample of states, school districts, schools, 

and teachers since the National Assessment of the Implementation of Title I was completed in 2006. 

Since that time, a number of policy initiatives have been implemented. Similarly, Title II expanded the 

number of policy initiatives applicable to most school districts and schools and has not been studied 

using a nationally representative sample. These data will provide policy makers with detailed 

information on how these initiatives are playing out in states, school districts, schools and classrooms.

Collecting the data less frequently would leave policymakers and the public poorly informed about the 

progress of current federal and state education reform initiatives.

A.7. Special Circumstances Requiring Collection of Information in a Manner 

Inconsistent with Section 1320.5(d)(2) of the Code of Federal 

Regulations

There are no special circumstances involved with this data collection.

A.8. Federal Register Comments and Persons Consulted Outside the 

Agency

The 60-day Federal Register notice was published on July 11, 2013 Vol 78, page 41785. There were no 

public comments on the package. 

A Technical Working Group (TWG) has been assembled for this study. The current TWG members are 

listed below. Additional consultation may be sought during later phases of the study (e.g., data analysis).

 Christopher Cross, Chairman, Cross & Joftus

 Daria Hall, Director of K-12 Policy Development, The Education Trust

 David Heistad, Executive Director of Research, Evaluation, and Assessment, Minneapolis Public 

Schools

 Eugenia Kemble, Executive Director, Albert Shanker Institute

 Sharon Lewis, Director of Research, Council of the Great City Schools
9

 Thomas Payzant, Professor of Practice, Harvard Graduate School of Education

 Sean Reardon, Associate Professor, Administration & Policy Studies, Stanford University

 Judy Wurtzel, Consultant, Education Policy

 Grover Russ Whitehurst, Chair and Director of the Brown Center on Education Policy, Brookings 

Institution

A.9. Payments to Respondents

We propose to provide teachers with a $20 incentive (e.g., gift card, check, or money order) and 

principals with a $25 incentive for completing the surveys. Some of the schools in the study sample will 

not receive Title I or Title II funds directly. We recognize that teachers and principals have many 

demands on their time, and we expect that the incentives will reduce the non-response follow-up (and 

associated costs) necessary to achieve the desired response rate of at least 85%. The non-response 

follow-up costs are non-trivial since the study sample includes teachers and principals in 1,300 schools 

from all 50 states and DC. The recent Integrated Evaluation of the American Recovery and 

Reinvestment Act (ARRA) NCEE study did not include principal incentives, and the response rate for the 

first administration of the principal survey was lower than 80%.

We expect the incentive to: increase teacher and principal interest and encourage teachers and 

principals to prioritize participation over other activities that do not provide a monetary reward; 

improve the quality of the data; and partially compensate teachers’ and principals’ time and effort, in 

acknowledgment of the time required to complete the surveys (a 30 minute survey for teachers and a 

30 minute survey as well as a teacher roster for principals). The proposed $20 and $25 incentives are 

within the incentive guidelines outlined in the March 22, 2005 memo, “Guidelines for Incentives for 

NCEE Evaluation Studies,” prepared for OMB.

Recent research indicates positive effects on response rates for the use of cash incentives. For example, 

Cantor, O’Hare and O’Connor (2007) found that promised incentives of $15 – $35 increase response 

rates. In another study, researchers found that providing incentives for early non-respondents boosted 

response rates (Zagorsky & Rhoton, 2008). Finally, in a recent review of the incentive use in longitudinal 

surveys, Laurie and Lynn (2009) concluded that respondent incentives are an important element in 

minimizing attrition for longitudinal surveys. 

A.10. Assurance of Confidentiality

Other than the names and contact information for the survey respondents and teachers that will make 

up the teacher sampling frame, which is information typically already available in the public domain (i.e., 

state, district, and school websites) no data collected for surveys will contain personally identifiable 

information. No names and contact information will be released. 

Responses will be used for research or statistical purposes. States and districts receiving Title I and Title 

II funds have an obligation to participate in Department evaluations (Education Department General 

Administrative Regulations (EDGAR) (34 C.F.R. § 76.591)). Participation is voluntary for principals and 

teachers. 

The following language will be included on the cover sheet of district, school, and teacher surveys, and 

the teacher roster under the Notice of Confidentiality: Information collected for this study comes under 
10

the confidentiality and data protection requirements of the Institute of Education Sciences (The 

Education Sciences Reform Act of 2002, Title I, Part E, Section 183). Responses to this data collection will 

be used only for statistical purposes. The reports prepared for the study will summarize findings across 

the sample and will not associate responses with a specific district or individual. We will not provide 

information that identifies you or your district to anyone outside the study team, except as required by 

law.

On the state survey, we will modify the Notice of Confidentiality statement to replace references to 

“district” with “state.” However, while individual states may be identified in reporting, individual 

respondents will not be identified.

The Education Sciences Reform Act of 2002, Title I, Part E, Section 183 of this Act requires, “All 

collection, maintenance, use, and wide dissemination of data by the Institute” to “conform with the 

requirements of section 552 of title 5, United States Code, the confidentiality standards of subsection (c) 

of this section, and sections 444 and 445 of the General Education Provision Act (20 U.S.C. 1232g, 

1232h).” Respondents will be assured that confidentiality will be maintained, except as required by law. 

Specific steps to guarantee confidentiality include the following:

 Identifying information about respondents (e.g., respondent name, address, and telephone 

number) will not be entered into the analysis data file, but will be kept separate from other data 

and will be password protected. A unique identification number for each respondent will be 

used for building raw data and analysis files.

 A fax machine used to send or receive documents that contain confidential information will be 

kept in a locked field room, accessible only to study team members. 

 Confidential materials will be printed on a printer located in a limited access field room. When 

printing documents that contain confidential information from shared network printers, 

authorized study staff will be present and retrieve the documents as soon as printing is 

complete.

 In public reports, findings will be presented in aggregate by type of respondent or for subgroups 

of interest. No reports will identify individual respondents or local agencies. 

 Access to the sample files will be limited to authorized study staff only; no others will be 

authorized such access.

 All members of the study team will be briefed regarding confidentiality of the data. 

 Most data will be entered via the web systems. However, a control system will be established to 

monitor the status and whereabouts of any hard copy data collection instruments during data 

entry. 

 All data will be stored in secure areas accessible only to authorized staff members. Computergenerated output containing identifiable information will be maintained under the same 

conditions.

 Hard copies containing confidential information that is no longer needed will be shredded. 

A.11. Questions of a Sensitive Nature
11

There are no questions of a sensitive nature asked in any of the surveys.

A.12. Estimates of Respondent Burden

Beginning in January 2014, surveys will be administered to respondents in:

 The 50 states and the District of Columbia,

 570 sampled school districts ,

 1,300 sampled schools (within the sampled school districts), and

 9,100 sampled core academic and special education teachers (within the sampled districts and 

schools).

School principals in 1,300 sampled schools will be asked to complete a teacher roster.

In all, responses will be required from 12,321 respondents (51 state officials for the state survey; 570 

district officials for the district survey; 1,300 principals; 1,300 school officials for the teacher roster; and 

9,100 teachers). Although we expect that at the state and district levels, there may be more than one 

respondent completing the survey, we are estimating the burden to complete the total survey as one 

respondent per state/district times the number of minutes for the total survey.

Based on the survey piloting, we estimate that it will take (1) state respondents an average of 180

minutes (in total, summed across multiple respondents in each state working on separate survey 

sections) for the survey and follow-up, (2) district respondents an average of 60 minutes for the survey,

(3) principal respondents an average of 30 minutes for the survey, (4) school respondents an average of 

30 minutes to complete the teacher roster, and (5) teacher respondents an average of 30 minutes to 

complete the teacher survey, so total burden for the 2013-2014 data collection is 394,380 minutes or 

6,573 hours (see Table A - 2 below). 
12

Table A - 2. Estimates of respondent burden

Informant/Data Collection Activity #

of R

esp

o

n

d

e

nts

Min

utes p

er

co

m

pletio

n

N

u

m

b

er of

ad

ministratio

ns

B

urd

e

n in

min

utes

T

otal B

urd

e

n

H

o

urs

T

otal C

osts

State

SEA survey and Follow-up 51 180 1 9,180 153 $6,646.32

District

District survey 570 60 1 34,200 570 $24,760.80

School

Principal survey 1,300 30 1 39,000 650 $28,236.00

Teacher roster 1,300 30 1 39,000 650 $28,236.00

Teacher survey 9,100 30 1 273,000 4,550 $122,395.00

Total 12,321 330 1 394,380 6,573 $210,274.12

NOTE: Assumes an hourly rate of $43.44 per hour for educational administrators and an hourly rate of $26.90 for teachers 

(derived from the Bureau of Labor Statistics’ Occupational Employment and Wages for educational administrators and teachers, 

May 2011).

A.13. Estimates of the Cost Burden to Respondents

There is no annualized capital/startup or ongoing operation and maintenance costs associated with 

collecting the information.

A.14. Estimates of Annualized Government Costs

The amount for the design, conduct of two rounds of surveys and analysis, and reporting for the base 

contract for this study is $9,341,945. The annualized cost over five years is $1,868,389.

A.15. Changes in Hour Burden

This is a new collection. There is a program change resulting in an increase in burden and responses of 

6,573 hours and 12,321 responses.

A.16. Time Schedule, Publication, and Analysis Plan

The report will follow the principles of the Federal Plain Language Action and Information Network and 

adhere to the requirements of the NCES Statistical Standards (2002), IES Style Guide (2005) and other 

IES guidance and requirements for public reporting.
13

The focus of the report will be on the progress made on the core policies promoted by Titles I and II. It 

will not address Title I/II funding or administrative issues. The analyses in the report will not try to 

separate the influence of Titles I and II from that of other Federal and state reform initiatives that have 

arisen since the previous National Assessment of Title I.

This first study report will answer a clearly established set of questions using information from the state, 

district, school, and teacher surveys and extant sources of data. The report will start with an outline of 

highlights. The body of the report will contain five chapters, each addressing one of the major themes of 

the study and the corresponding research question. Each chapter will have a brief context section 

summarizing the provisions of Titles I and II that embody policy-relevant issues in each area, and how 

these policies have evolved since the No Child Left Behind Act of 2001 (NCLB). The report will include 

information at each level—state, district, school, and teacher. 

We anticipate beginning to field the SEA, district, principal, teacher roster, and teacher surveys in 

January 2014. We expect that the baseline report based on these data will be available during summer 

2015. 

The report described above will be supported by analyses that will have three main objectives: (1) 

describing the extent to which policy and program initiatives related to the objectives of Title I and Title 

II are being implemented at the state, district, and school levels, including how implementation varies by 

selected state, district, school, and teacher characteristics; (2) describing patterns of cross-level 

implementation; and (3) describing trends in student achievement since the last Title I report. Each set 

of planned analyses is described below.

A.16.1. State, District, and School Level Implementation

The primary goal of the study is to describe the implementation of policy and program initiatives related 

to the objectives of Title I and Title II. To achieve this goal, extensive descriptive analyses will be 

conducted using survey data and data derived from the review of state documents. We anticipate that 

relatively straightforward descriptive statistics (e.g., means, frequencies, percentages) and simple 

statistical tests (e.g., tests for differences of proportions) will typically be used to answer the research 

questions detailed in section A.1 above.

While simple descriptive statistics such as means and percentages will provide answers to many of our 

questions, cross-tabulations will be important to answer questions about variation across state, district, 

school, and teacher characteristics. The primary characteristics of interest for the cross-tabulations are:

 Whether a state received an approved ESEA Flexibility request from the U.S. Department of 

Education.3This is of interest because ESEA Flexibility is expected to influence the design of 

state accountability systems and approaches to educator quality measurement and policy 

makers will be interested in what states do with the ESEA Flexibility.

 District poverty level, size, urbanicity, and concentration of English learners. Poverty is included 

because Title I is specifically intended to ameliorate the effects of poverty on local funding 

 

3 For the purposes of the baseline survey, we consider ESEA Flexibility states as those states with an approved ESEA Flexibility request and are 

expected to implement the Flexibility policies during the 2013-14 school year.
14

constraints and educational opportunity. Urbanicity is included because of the relationships 

between educational opportunity and rural isolation and the concentration of poverty in urban 

schools. Size is included because it may be related to district capacity to develop and implement

programs. Concentration of English learners is included because of the increased emphasis on 

ensuring that this group of students also meets state content standards and recognition that 

modifications in testing as well as instruction will be needed to facilitate progress of these 

students.

 School Title I status, grade span (high school, middle, and elementary grades), poverty level, and 

cross classifications of Title I status and poverty level. Grade span is included because the 

implementation of state content standards and aligned assessments as well as responses to 

accountability systems likely differs by grade level. Title I status is included because the focus of 

Title I funds and requirements is to influence state and district policy and school effectiveness. 

We plan to cross-classify Title I status with school poverty because there may be substantial 

differences between what happens in high-poverty Title I schools in comparison with Title I 

schools with low/medium-poverty levels, which may be more similar to schools which do not 

receive Title I funding. 

 Teacher grade span taught and whether the teacher teaches a grade or subject in which state 

testing is required by ESEA. These characteristics are included because teachers’ responses to 

state content standards, assessments, accountability systems, and teacher evaluations based on 

student growth may vary by grade span, and by whether they teach tested subjects or grades.

Because of the use of a statistical sample, survey data presented for districts, schools, and core 

academic and special education teachers will be weighted to national totals (tabulations will provide 

standard errors for the reported estimated statistics). In addition, the descriptive tables will indicate 

where differences between subgroups are statistically significant. We will use Chi-Square tests to test 

for significant differences among distributions and t-tests for differences in means. Tabulations will be 

included in the reports where appropriate.

A.16.2. Cross-Level Analysis

The planned cross level analyses involve examining responses of districts, schools, or teachers by 

categories of responses from units at the next level. Examining data across levels has two purposes. The 

first is to examine the presence of key requirements in state and district policies that influence 

educators. For example:

 Whether in states that adopted new or revised content standards, core academic and special 

education teachers received professional development on the state content standards and 

supporting materials to facilitate teaching to the state content standards; and

 Whether in districts that use student growth to evaluate teachers, core academic and special 

education teachers experienced professional development opportunities that helped them 

improve student growth.

The second goal of cross-level analysis is to examine the relationship between policies and programs 

originating at the state or district level and implementation “on the ground” in schools and classrooms.
15

Though the planned analyses cannot support causal conclusions about the effects of state and district 

actions on school and classroom implementation, they can provide evidence on the extent to which 

school and classroom practices are consistent with higher-level policies.

Conceptually, these analyses posit that certain state and district policy choices influence what happens 

at the school and classroom level. Examples of potential cross-level analyses include:

 Whether core academic and special education teachers in states that provide more extensive 

support for teachers to use state content standards are more likely to report using the state 

content standards in their classrooms than teachers in other states; 

 Whether districts in states that have been granted ESEA Flexibility are less likely to require after 

school academic services to students in low-performing schools than districts in other states;

and

 Whether principals in districts that report using student growth to evaluate teachers consider 

growth results when planning professional development for teachers.

These cross-level analyses will be based on cross-tabulations. For example, a straightforward set of 

descriptive tables will show the relationships between survey responses at one level and the mean

responses at the lower level or percents of lower-level units (e.g., principals or teachers) responding in a 

certain way. Breakdowns by the previously discussed state, district or school characteristics will further 

sharpen the interpretation of these relationships.

A.16.3. Student Achievement Trends

We will conduct a descriptive analysis of cross-state trends in student proficiency levels, using state-level 

NAEP results and statewide results on state assessments. This analysis will address the research 

questions of whether students are making progress on meeting state academic achievement standards 

within states and how this progress varies across states. The analysis will be entirely descriptive and will 

not attempt to derive any causal inferences. The analysis will utilize two data sources:

 State-by-state NAEP proficiency rates since 2007, math, reading, and science, grades 4, 8, 

and 12; and

 State-by-state proficiency rates on each state’s own assessments since 2007, math and 

reading, grades 4, 8, and 9-12 (from EDFacts and state web sites)

The results of this analysis will consist of a comparison of changes in student proficiency levels across 

states. For each state and for the nationwide average we will present the following information:

 Percent proficient on NAEP, in 2007 and most recent year, and the difference between 

the two years;

 Percent proficient on state assessments, in 2007 and the most recent year, and the 

difference between the two years; and
16

 The difference between the percent proficient on NAEP and the percent proficient on the 

state assessment, in 2007 and the most recent year, and the difference between the two 

years

For each of these items we will report results separately for math and reading, and for grades 4, 8, and 

12, as well as aggregated across both subjects and grades. NAEP assessments are given in grade 12, but 

the tested high-school grade(s) on state assessments vary across states, and we will report results for 

the tested high-school grade(s) for each state. Additionally, we will report the percentage of states that 

are improving, declining, or remaining the same in their proficiency rates since 2007, for both NAEP and 

the state assessments.

A.17. Display of Expiration Date for OMB Approval

The Institute of Education Sciences is not requesting a waiver for the display of the OMB approval 

number and expiration date. The surveys (Appendixes A through D), teacher roster (Appendix E), and 

notification letters (Appendix F) will display the expiration date for OMB approval.

A.18. Exceptions to Certification Statement

This submission does not require an exception to the Certificate for Paperwork Reduction Act (5 CFR 

1320.9).
17

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