# 2015 **- 16 NATIONAL POSTSECONDARY** 

**STUDENT AID STUDY (NPSAS:16)**

**Full Scale Institution Contacting**  **and Enrollment List Collection Supporting Statement**  **Part A (OMB # 1850**  **- 0666**  **v. 1**  **5 )** 

**Submitted by National Center for Education Statistics** 

**U.S. Department of Education**

**Ap ril**  **23, 2015** ii 

## Contents **A. Justification**  **................................ ................................**  **................................ ................................**  **...... 1**  1. Circumstances Making Collection of Information Necessary ................................ ................................ ...... 1 a. Purpose of this Submission ................................ ................................ ................................ ........................ 1 b. Legislative Authorization ................................ ................................ ................................ ............................ 2 c. Prior NPSAS Studies ................................ ................................ ................................ ................................ ... 2 d. Prior and Related Studies ................................ ................................ ................................ ............................ 3 2. Purposes and Uses of the Data ................................ ................................ ................................ .......................... 3 a. NPSAS:16 Purposes ................................ ................................ ................................ ................................ ..... 3 b. NPSAS:16 Research and Policy Issues ................................ ................................ ................................ ..... 4 3. Use of Information Technology ................................ ................................ ................................ ........................ 6 4. Efforts to Identify Duplication ................................ ................................ ................................ .......................... 6 5. Method Used to Minimize Burden on Small Businesses ................................ ................................ .............. 6 6. Frequency of Data Collection ................................ ................................ ................................ ............................ 7 7. Special Circumstances of Data Collection ................................ ................................ ................................ ....... 7 8. Consultants Outside the Agency ................................ ................................ ................................ ....................... 7 9. Provision of Payments or Gifts to Respondents ................................ ................................ ............................ 7 10. Assurance of Confidentiality ................................ ................................ ................................ .............................. 7 11. Sensitive Questions ................................ ................................ ................................ ................................ ............ 10 12. Estimates of Response Burden ................................ ................................ ................................ ........................ 10 13. Estimates of Cost ................................ ................................ ................................ ................................ ............... 11 14. Costs to Federal Government ................................ ................................ ................................ ......................... 11 15. Reasons for Changes in Response Burden and Costs ................................ ................................ ................. 11 16. Publication Plans and Time Schedule ................................ ................................ ................................ ............. 11 17. Approval to Not Display Expiration Date for OMB Approval ................................ ................................ 11 18. Exceptions to Certification for Paperwork Reduction Act Submissions ................................ ................. 12 **B. Collection of In** **formation Employing Statistical Methods &**  **References C.**  **Additional Enrollment List Items Justification Appendixes**  A. Studies Addressing Issues Relevant to NCES’ Postsecondary Longitudinal and Sample Surveys Studies Program B. Technical Review Panel Members C. Confidentiality Agreement D. Letters , Contacting Materials, and Website Content E. Script for Eligibility Screening Calls F. Endorsing Associations for NPSAS:16 G. Information Collected through the Institution Registration Page and Enrollment Lists **Tables Page**  Table 1. Chronology of NPSAS and its longitudinal components ................................ ................................ ................................ . 3 Table 2. Maximum estimated burden on institutions for the NPSAS:16 full sca le enrollment list collection ..................... 10 Table 3. Individual and total costs to NCES for the NPSAS:16 field test and full
- scale implementations ......................... 11 Table 4. Contract costs for NPSAS:16 ................................ ................................ ................................ ................................ ............. 12 Table 5. Operational schedule for NPSAS:16 ................................ ................................ ................................ ................................ 121 

### A. **Justification 1.**  **Circumstances Making Collection of Information Necessary**  **a. Purpose of this Submission**  This d ocument supports the clearance of materials and procedures for institution sampling and contacting, and enrollment list collection for the full scale of the 2015
- 16 National Postsecondary Student Aid Study (NPSAS:16). This study is being conducted by the N ational Center for Education Statistics (NCES), within the Institute of Education Sciences (IES), part of the U.S. Department of Education. The primary contractor for this study is RTI International (Contract # ED
- IES
- 13
- C
- 0070) , and subcontractors include Coffey Consulting; H ERMES ; HR Directions; KF orce Government Solutions, Inc.; Research Support Services; Shugoll Research; and Strategic Communications, Inc. Consultants are Dr. Sandy Baum , Ms. Alisa Cunningham , and Dr. Stephen Porter . This submission covers NPSAS:16 full scale materials and pro cedures required for institution sampling and contacting, and the enrollment list collection and sampling . NCES will submit a separate clearance package covering the student data collection in the fall of 2015 . The materials to be used in the full scale NPSAS collection are based upon those that were approved for the field test (OMB# 1850
- 0666 v.12
- 14) . With th ose submission s , NCES adequately justified the need for and overall practical utility of the full study, an overarching plan for all phases of the data collection, and provided as much detail on the measures to be used as was available at the time of the submission. As part of th e field test submission, NCES publish ed a notice in the Federal Regis ter allowing first a 60
- and then a 30
- day public comment period. For this submission , NCES publish ed a notice in the Federal Register allowing an additional 30
- day public comment period on the final details of the 2015
- 16 full
- scale study described in thi s submission. NPSAS:16 is a nationally representative study of how students and their families finance education beyond high school. The first NPSAS was implemented by NCES during the 1986
– 87 academic year to meet the need for national
-level data about significant financial aid issues. Since 1987, NPSAS has been fielded every 3 to 4 years, most recently during the 2011
– 12 academic year. This submission is for the ninth cycle in the series focused on the 2015
– 16 academic year. NPSAS:16 also will serve as the base year data collection for the 2016 Baccalaureate and Beyond Longitudinal Study (B&B), a study of college graduates one year (B&B:16/17), four years (B&B:16/20), and ten years (B&B:16/26) following completion of requirements for the bachelor’s degree. Subsets of questions in the student interview will focus on describing aspects of the experience of B&B
- eligible students in their last year of postsecondary education, including student debt, entry to graduate school, and the transition to employment and career. This submission includes:  A list of p revious studies related to or based on data from NPSAS or its longitudinal spin
- offs (Appendix A);  A membership list of the Technical Review Panel (TRP) for the institution data collection component of NPSAS:16 (Appendix B);  The Confidentiality Agreement completed by all project staff having access to individually identifiable data (Appendix C);  Introductory letters to institutions and students selected for participation in the NPSAS:16 study (Appendix D);  The script used by institutional contactors to verify eligibility and confirm contact information with sampled institutions (Appendix E);  A list of endorsing institutions and associations s upporting NPSAS:16 (Appendix F); and  Information c ollected through the Institution Registration Page and Enrollment Lists .2

**b. Legislative A**  **uthorization** NPSAS:16 is conducted by NCES in close consultation with other U.S. Department of Education offices , federal agencies, and organizations. NPSAS is authorized under the Education Sciences Reform Act (ESRA) of 2002 (20 U.S.C. § 95 43) and the Higher Education Opportunity Act (HEOA) of 2008, 20 U.S.C. § 1015: (A)(k) Student aid recipient survey (1) Survey required: The Secretary, acting through the Commissioner for Education Statisti cs, shall conduct, on a State
by
- State basis, a survey of recipients of Federal student financial aid under Title IV
— (A) to identify the population of students receiving such Federal student financial aid; (B) to describe the income distribution and other socioeconomic characteristics of recipients of such Federal student financial aid; (C) to describe the combinations of aid from Federal, State, and private sources received by such recipients from all income categories; (D) to describe the
— (i) debt burde n of such loan recipients, and their capacity to repay their education debts; and (ii) the impact of such debt burden on the recipients’ course of study and post
- graduation plans; (E) to describe the impact of the cost of attendance of postsecondary education in the determination by students of what institution of higher education to attend; and (F) to describe how the costs of textbooks and other instructional materials affect the costs of postsecondary education for students. (2) Frequency: The survey shall be conducted on a regular cycle and not less often than once every four years. (3) Survey design: The survey shall be representative of students from all types of institutions, including full
- time and part- time students, undergraduate, graduate, and professional students, and current and former students. (4) Dissemination: The Commissioner for Education Statistics shall disseminate to the public, in printed and electronic form, the information resulting from the survey. **c. Prior NPSA** **S Studies** As noted above, NPSAS:16 will be the ninth NPSAS in a series dating back to 1986
– 87. The first in the series, NPSAS:87, based on a sample of students enrolled in the fall term of 1986, is not completely comparable to later studies. Beginning in 1989
–90, NPSAS surveys sampled students enrolled at any time during a full academic year, so that students enrolled only during the summer or spring terms, as well as those who began at any time in institutions not on a traditional calendar system (primarily vocational institutions) , were included. In NPSAS:87 and NPSAS:12, institutions in Puerto Rico were not sampled. Additional detailed information about each of the prior NPSAS studies and related longitudinal studies conducted by NCES is provided at http://nces.ed.gov/surveys/npsas/ . Since its inception, the data collection techniques, sources, and sampling and weighting methods used for NPSAS have evolved to meet increasing demand for more precise and detailed information to inform postsecondary student financial aid policy. Following NPSAS:87, which combined paper
- based surveys of 40,000 students and a subset of their parents with institutional records, NPSAS:90 introduced computer
assisted telephone interviewing and incorporated data from the federal Pell Grant payment file. NPSAS:93 enabled institutions to enter student records electronically, and NPSAS:96 added as data sources the Central Processing System for federal financial aid applications, the National Student Loan Data System, and SAT and ACT student test scores. NPSAS:2000 dropped the parent interview and expanded the sample size to 60,000 students. NPSAS:04 introduced a self
- administered web
- based student interview option, further increased the sample size to 110 ,000 students and , for the first time , oversampled undergraduate students in 12 states to permit state
- representative estimates for those states. NPSAS:08 retained state
- representative oversamples for six states, enlarged the sample size to 130,000 student s, and added the National Student Clearinghouse (NSC) as an administrative data source. NPSAS:12 , in response to the growing for
- profit sector and to ensure reliable estimates at all institution levels, dropped the state
- representative samples , but added s eparate sampling for all levels of the for
- profit sector: less
- than
- 2
-year, 2
-year, and 4
-year institution s . In addition, NPSAS:12 was the first cycle to use current-year 12
- month institutional enrollment data to ensure more accurate poststratification (weighting) than was achieved using prior
-year enrollment data.3

**d. Prior and Related Studies**  Two longitudinal studies conducted within the Sample Surveys Division of NCES were designed to address a variety of issues regarding higher education. Based on samples o f students enrolled for postsecondary education in a particular year regardless of age, each of these studies incorporates base year data from the cross - sectional NPSAS and extends it through longitudinal follow
- up components focusing on first
- time student s and on recent college graduates in alternate NPSAS survey years: Beginning Postsecondary Students (BPS) and Baccalaureate and Beyond (B&B). The chronology of the previous administrations of the NPSAS study and its associated longitudinal components is presented in table 1. **Table 1. Chronology of NPSA** **S and its longitudinal components** Base year First follow- up Second follow- up Third follow- up NPSAS:90 BPS:90/92 BPS:90/94 — NPSAS:93 B&B:93/94 B&B:93/97 B&B:93/03 NPSAS:96 BPS:96/98 BPS:96/01 — NPSAS:2000 B&B:2000/01 — — NPSAS:04 BPS:04/06 BPS:04/09 — NPSAS:08 B&B:08/09 B&B:08/12 B&B:08/18 (anticipated) NPSAS:12 BPS:12/14 BPS:12/17 — NPSAS:16 B&B:16/17 B&B:16/20 (anticipated)

— Not applicable. NOTE: BPS = Beginning Postsecondary Students; B&B = Baccalaureate and Beyond. The seven major issues addressed in these Sample Surveys Division studies are: 1. Undergraduate access/choice of institution; 2. Persistence; 3. Progress/curriculum; 4. Attainment/outcome assessment; 5. Financial aid and student debt; 6. Access to graduate programs; and 7. Benefits of postsecondary education to individuals and society. Specific studies that explore some of these issues and have been based on previous NPSAS, BPS, or B&B data are listed in appendix A for reference. **2. Purposes and Uses of t**  **he Data** This section provides information on the purposes of NPSAS, and an overview of the primary research issues it addresses.

**a. NPSA** **S:16 Purposes** The fundamental purpose of NPSAS is to create a research data set that brings together information about a variety of programs for a large sample of undergraduate and graduate students. NPSAS provides the data for comprehensive descriptions of the undergraduate and graduate student populations in terms of their demographic characteristics, academic programs, type s of institutions attended, attendance patterns, and employment. Demographic and enrollment data establish the appropriate context that allows researchers and policy analysts to address basic issues about postsecondary affordability and the recipients of s tudent financial assistance . These results are presented in multiple publications, including: a First Look report; four Web Table publications covering student aid by institutional sector, a profile of undergraduates, undergraduate financing, and a profile of graduate students , including education financing beyond the bachelor’s degree; and a Statistics in Brief report, which describ es the total price of attendance for undergraduates, net price after grant aid, and the “out
- of

- pocket” net price.4

The data can be used to calculate statistics with PowerStats , QuickStats, and TrendStats, web
- based software applications available to the public at http://nces.ed.gov/datalab , and to qualified researchers through the IES restricted
- use data licensing program. A second purpose of NPSAS is to gather base
-year data on a subset of students who become the sample for a longitudinal study. NPSAS:16 will establish the base year cohort for a B&B study of bachelor’s degree recipients, with a follow
- up survey one year later (B&B:16/17) and additional follow
- ups anticipated in 2020 and 2026. A section of the student interview will capture information about students’ graduate school and career plans to support analysis of graduate education and employment outcomes , with a special emphasis on students considering and pursuing careers in elementary and secondary teaching. A third purpose of NPSAS is to provide a nationally representative sample that can be used to rigorously address fundamental research questions through experimental research methodologies. NCES plans to expand the use of NPSAS through collaboration with the National Center for Education Research (NCER). NPSAS provides a rich source of d ata that could be used to support experimental research funded by NCER. Interested researchers have been asked to submit a proposal detailing their experimental design and analysis plans. Upon grant review and approval, RTI will conduct any needed data col lection and/or file

- matching activities and deliver a restricted data file to NCES to provide to the grantee for analysis. Currently, proposals are due to NCER o n August 6, 2015 , and awards are expected in early summer 2016 .

**b. NPSA** **S:16 Research and Policy Is**  **sues** Many of the important questions that NPSAS:16 aims to address are the same as in the past years. Price increases, net price levels, and increases in student loan debt will continue to be central issues. The NPSAS:16 data will be used to address policy issues related to changes in federal financial aid programs resulting from the anticipated reauthorization of the Higher Education Act. Some of the primary research and policy issues to be addressed through the use of NPSAS:16 data will be: (1) Student de mographics;

 What is the distribution of student enrollment among types of institutions by gender, race/ethnicity, age, dependency, and income?

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

y students?

 What proportion of undergraduates are first generation college students, and what types of institutions are they attending?

 What proportion of students are immigrants or children of immigrants, and what types of institutions are they attending?

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

 What proportion of students enrolled in postsecondary education are active military or veterans and what types of institutions do they attend? (2) Academic preparation and p rograms;

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

 What types of students are enrolled in vocational certificate, associate’s, and bachelor’s degree programs, and what are their fields of study?

 What is the extent of internet
- based and other distance education, for certain courses or for entire programs of study, and what types of institutions and students are using it?

 What are students’ primary purposes for enrolling in postsecondary education and their educatio nal goals?5

(3) Financial aid;

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

 What proportion of students has remaining need beyond what they receive in financial aid and what is the average amount of unmet need?

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

 What proportion of students are receiving aid from states, institutions, employers, and private sources, and what is the average amount received?

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

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

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

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

 What proportion of students receives veterans and other Department of Defense benefits, and how much do they receive?

 How has the incidence and average amount of Veterans’ benefits changed since the enactment of the Pos t- 9/11 GI Bill (P.L. 110

- 252)?

 How has the number and proportion of nonveterans receiving Veterans’ benefits as dependents of veterans changed since enactment of the Post
- 9/11 GI Bill (P.L. 110

- 252)?

 What types of institutions enroll the highest proportion s of active military personnel, veterans, and recipients of Veterans’ benefits? (4) Price of attendance;

 What are the differences in the average tuition and total price of attendance by type of institution and among students by dependency, income, and full
- time or part
- time attendance status?

 What is the average net price of attendance (student budget minus financial aid) at various income levels at different types of institutions? (5) Student borrowing;

 What are the differences in the percentage borrowing and the average amounts borrowed through the federal student loan programs by institution type, attendance status, class level, and income?

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

 What is the difference in the proport ion of students receiving subsidized or unsubsidized Direct (Stafford) loans by dependency and income level?

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

 What proportion of students borrows pr ivate loans, in what amount, and how does this borrowing vary by institution type?

 What proportion of students use credit cards to finance their education, and how much do they borrow? (6) Student employment;

 What proportion of students engage in paid work while enrolled and what are the average hours per week they work?6

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

 What proportion of students is employed by their institution in work
- study and graduate assistantships as compared with other typ es of employment? (7) Sources of funds;

 What types of financial support are dependent students receiving from their parents? Answers to these and other questions are vital if policymakers at the local, state, and national levels are to respond adequately to the changing environment of postsecondary education. As the publications listed in appendix A indicate, since inception, the NPSAS, BPS, and B&B series have resulted in numerous NCES publications addressing these issues. The data from these studies have also been used extensively to explore Sample Surveys division issues through the NCES Postsecondary Education Analysis Resources (PEAR) series.**3. Use of Information Technology**  To ensure the secure transmission of sensitive information on the student enrollment lists, we will allow institutions to either upload encrypted student enrollment list files to the project’s secure website using a login ID and strong password provided by RTI , or provide an appropriately encrypted list file via e
- mail. We do not expect that institutions will ask to provide a paper list, but RTI has protocols in place for handling faxed materials. The original file and any paper list containing Social Secur ity numbers (SSNs) will be kept through data collection in order to resolve any issues with student identification that occur during data collection and then the files will be deleted and the lists shredded after data collection is completed . RTI will ensure that SSNs for non
- selected students are securely discarded immediately following sampling . **4. Efforts to Identify Duplication**  Efforts to identify duplication have included NCES consultations with other federal offices, such as the U.S. Department of Educat

ion’s Office of Postsecondary Education; the Office of Planning, Evaluation and Policy Development; and other agencies, such as the Government Accountability Office; the Congressional Budget Office; and the Office of Management and Budget. In addition, NCE S collaborates with the National Center for Science and Engineering Statistics (NCSES) at the National Science Foundation (NSF) to ensure that each unit is kept up
- to - date on each other’s studies pertaining to postsecondary students and institutions. NCES and NSF meet on a regular basis to cover topical issues relevant to both offices and each has staff serving on study technical review panels. NCES routinely consults with non
- federal associations, such as the American Council on Education, the Association of Private Sector Colleges and Universities, the National Association of Student Financial Aid Administrators, the National Association of Independent Colleges and Universities, the Council of Graduate Schools, and the Institute for Higher Education Policy to confirm that data collected through NPSAS are not available from any other sources. NCES also consults with academic researchers, several of whom attend the NPSAS Technical Review Panel meetings. Beyond identification of duplication, these consultation s provide methodological insights from the results of similar and related studies conducted by NCES, other federal agencies, and nonfederal sources. The consultations also assure that data collected through NPSAS will meet the needs of the federal government and relevant organizations. No studies in the U.S duplicate the data produced by NPSAS. **5. Method Used to Minimize Burden on Small Businesses**  The burden associated with enrollment list collection is relatively minor for all institutions, including small bu sinesses that may be contacted as part of the NPSAS:16 full scale (for
- profit schools and other small public and private schools). NPSAS:16 is asking for a minimal set of variables on the enrollment lists, and institutions will be offered alternative metho ds of providing requested data, including uploading to a secure website or emailing encrypted list files. We will attempt to minimize the intrusion and burden to such schools7

by working closely with a school
- appointed coordinator before the data collection effort to identify the sources of information within the school and the format in which records are kept. We have also discussed enrollment list variables with the technical review panel to ensure that the request is minimally burdensome and consistent with typical recordkeeping at postsecondary institutions. **6. Frequency** 

**of Data Collection** This cycle of NPSAS will take place 4 years after the last data collection. The large
- scale and rapid changes in federal policy concerning postsecondary student aid necessitate frequent studies. Eligibility restrictions change, size of grant and loan amounts fluctuate, and the balance between various aid options changes dramatically. Since these changes affect students’ ability to finance postsecondary education and the level of debt that students are accumulating, data collections every 3 to 5 years are necessary. A recurring study is essential in helping predict future costs for financial aid because loan programs create continued obligations for the federal government as long as the loans are being repaid. Repeated surveys like NPSAS are also necessary because of the dynamic nature of the postsecondary environment. For example, for
- profit institutions have recently a much more prominent role than was the case in years past . Changes in private
- sector lending, increases in tuition and fees, and changes in federal student aid policies (such as the recent increase in maximum Pell Grant awards) further highlight the need for periodic data collections. Effects of these changes on federal policy and postsecondary education participation create an opportunity, as well as a need, for monitoring on a regular basis. **7. Special Circumstances of Data Collection**  No special circumstances of data collection are anticipated. **8. Consultants Outside**  **the A gency**  Recognizing the significance of NPSAS data collection, several strategies have been incorporated into the project work plan that allow for the critical review and acquisition of comments relating to project activities, interim and final product s, and projected and actual outcomes. These strategies include consultations with persons and organizations both internal and external to NCES, the U.S. Department of Education, and the federal government. Previous NPSAS implementations have benefited from a technical review panel composed of staff from several offices in the Department; representatives of NSF, OMB, and CBO; and non
- federal members who are considered experts in postsecondary education issues , including financial aid (a list of the TRP m embe rs is provided in appendix B). Three technical review panel meetings have been held to inform the NPSAS:16 data collection. Another meeting is scheduled for August 2015 to discuss the results of the field test and review plans for the 2016 full
- scale study design. Subsequent to the TRP meeting, a separate request, related to student
-level data collection activities, specifically, the student interviews and student record collection from institutions, will be submitted for OMB ’s review . **9. Provision of Payments**  **or Gifts to Respondents** No payments or gifts to responding institutions will be given. **10. As**  **surance of Confidentiality** NCES assures participating individuals and institutions that all identifiable information collected under NPSAS and related programs may be used only for statistical purposes and may not be disclosed, or used, in identifiable form for any other purpose except as required by law [Education Sciences Reform Act of 2002 (ESRA), 20 U.S.C. § 9573]. NPSAS:16 data se curity and confidentiality protection procedures are in place to ensure that RTI and its subcontractors comply with all privacy requirements, including:8

 The Statement of Work of this contract;  Privacy Act of 1974 5 U.S.C. § 552(a);  The U.S. Department of E ducation Incident Handling Procedures (February 2009);  The U.S. Department of Education General Handbook for Information Technology Security General Support Systems and Major Applications Inventory Procedures (March 2005);  The U.S. Department of Education, ACS Directive OM: 5
- 101, Contractor Employee Personnel Security Screenings.  Family Educational and Privacy Act (FERPA) of 1974, 20 U.S.C. § 1232(g);  ESRA, 20 U.S.C. § 9573; and  All new legislation that impacts the data collected through this contract. RTI will comply with the Department’s IT security policy requirements as set forth in the Handbook for Information Assurance Security Policy and related procedures and guidance as well as IT security requirements in the Federal Information Security Managem ent Act (FISMA), OMB Circulars, and the National Institute of Standards and Technology (NIST) standards and guidance. All data products and publications will also adhere to the revised NCES Statistical Standards, as described at the website: http://nces.ed.gov/statprog/2012/ . The NPSAS:16 procedures for maintaining confidentiality include notarized nondisclosure affidavits obtained from all personnel who will have access to individual identifiers; personnel training regarding the meaning of confidentiality; controlled and protected access to computer files; built
-in safeguards concerning status monitoring and receipt control systems; and a secure, staffed, in
- house computing facility. NPSAS:16 follows detaile d guidelines for securing sensitive project data, including, but not limited to: physical/environment protections, building access controls, system access controls, system login restrictions, user identification and authorization procedures, encryption, an d project file storage/archiving/destruction. There are security measures in place to protect data during file matching procedures described in section 3. NCES has a secure data transfer system, which uses Secure Socket Layer (SSL) technology, allowing the transfer of encrypted data over the Internet. The NCES secure server will be used for all administrative data sources with the exception of the NSC which has its own secure FTP site. All data transfers will be encrypted. Study notification materials sent to institutions for student records will describe the voluntary nature of NPSAS:16 and convey the extent to which respondent identifiers and all responses will be kept confidential. The Department has established a policy regarding the personnel security s creening requirements for all contractor employees and their subcontractors. The contractor must comply with these personnel security screening requirements throughout the life of the contract. The Department directive that contractors must comply with is OM:5
- 101, which was last updated on 7/16/2010. There are several requirements that the contractor must meet for each employee working on the contract for 30 days or more. Among these requirements are that each person working on the contract must be assigne d a position risk level. The risk levels are high, moderate, and low based upon the level of harm that a person in the position can cause to the Department’s interests. Each person working on the contract must complete the requirements for a “Contractor Se curity Screening.” Depending on the risk level assigned to each person’s position, a follow
- up background investigation by the Department will occur. Regarding file matching with administrative sources, the Family Educational Rights and Privacy Act (FERPA) (34 CFR Part 99) allows the disclosure of information without prior consent for the purposes of NPSAS:16 according to the following excerpts: 34 CFR § 99.31 asks, “Under what conditions is prior consent not required to disclose information?” and explains in 34 CFR § 99.31(a) that “An educational agency or institution may disclose personally identifiable information from an education record of a student without the9

consent required by §99.30 if the disclosure meets one or more” of several conditions. These conditions include, at 34 CFR § 99.31(a)(6)(i): “The disclosure is to organizations conducting studies for, or on behalf of, educational agencies or institutions to: (A) Develop, validate, or administer predictive tests; (B) Administer student aid programs ; or (C) Improve instruction.” In addition, 34 CFR § 99.31(a)(6)(v) specifies: “For the purposes of paragraph (a)(6) of this section, the term organization includes, but is not limited to, Federal, State, and local agencies, and independent organizations.” All three parts of 34 CFR § 99.31(a)(6)(i) apply to NPSAS:16. The purpose of NPSAS:16 is to create a research data set for a large sample of students that brings together information about federal, state, and private aid programs, and gathers additional d emographic and enrollment data to establish the appropriate context. The resultant data set allows research and policy analysts to address basic issues about the affordability of postsecondary education and the effectiveness of the existing financial aid p rograms. The data set can be used for, or on behalf of, educational agencies or institutions to accomplish activities (A), (B), and (C). In 34 CFR § 99.31 (a)(6)(iii), FERPA further specifies that such disclosure may only occur if “[the] study is conducted in a manner that does not permit personal identification of parents and students by individuals other than representatives of the organization” and “[the] information is destroyed when no longer needed for the purposes for which the study was conducted.” Additionally, the study, including the administrative data linkage, qualifies for a 45 CFR Part 46 waiver of consent based on the following factors:  There is minimal risk to the participants. There is no physical risk and only minimal risk associated with linkage of data to sample members. The public
- use and restricted
- use data, prepared as part of the contract with RTI, will not include SSNs, even though these numbers are used for the linkage. Data will undergo disclosure avoidance analysis and disclosure treatment steps to further reduce the risk.  The waiver will not affect the rights and welfare of the subjects. The voluntary nature of the study is emphasized to sample members. Public
- use and restricted
- use data are only used for research purposes and lack direct individually
-identifying information. The data are further protected through disclosure avoidance procedures approved by the NCES Disclosure Review Board.  Whenever appropriate, subjects will be provided with additional pertinent information after they have participated. For each round of the study, information about prior rounds and the nature of the study is made available to sample members.  The study cannot be conducted practicably without the waiver. To obtain written consent from sample memb ers, multiple forms would have to be sent to the sample members with multiple follow
- up telephone and in
- person visits. This process would add weeks to the data collection process and is not feasible from a time standpoint. Additionally, the value of these data would be jeopardized from a nonresponse bias perspective.  The potential knowledge from the study is important enough to justify the waiver. These linked data for NPSAS:16 will provide invaluable data to researchers and education policy makers about the federal financial aid that students have received, as well as critical information concerning10

access to and persistence in postsecondary education. Rather than ask students for information about financial aid, we are getting it from the NSLDS, which is the Department’s system of recording federally aided student loans taken out and grants received by students. Students generally tend not to be a very reliable source of information about the amounts or timing of grants and loans they have received. This a dministrative record data is accurate and much easier to obtain than obtaining the same data by administering a questionnaire. **11. Sensitive Questions**  Institutions will be asked to provide personally
-identifying information for students on the enrollment lists (including name, contacting information, SSN, and date of birth (DOB)). Although considered sensitive, items collected on the enrollment lists will facilitate 1) identification of minors in the sample, 2) selection of the student sample, 3) initial tracing and locating activities, and 4) ongoing follow up with the baccalaureate cohort as part of the Baccalaureate and Beyond Longitudinal Study. Immediately after the student sample is selected, the SSNs for non
- selected students will be securely discarded. **12. E**  **stimates of Response Burden** Table 2 provides the p rojected estimates for response burden for NPSAS:16 , which are based on experiences from prior rounds of NPSAS. Using time burden data for similar institutional data collection tasks, we estimate the average burden associated with the enrollment list collection to be approximately 165 minutes per institution. The estimated hourly cost to institutions was raised from $17 for NPSAS:12 to $21 for NPSAS:16 to reflect salary increases at those institutions. The total estimated cost to institutions participating in the NPSAS:16 full scale enrollment list data collection for the 4,081 total burden hours is $ 8 5, 701 . This submission is for data collection of institution materials and enrollment lists only. We will sub mit b urden estimates for data collection from and about sampled students in a separate package in fall 2015 . The response time for participating institutions will vary based on how institutions keep their records and how easily they can extract the requested information. First, eligibility
- screening calls will be made to each sampled institution to confirm eligibility and verify contact information prior to mailing study information. Next, eligible institutions will be asked to complete an Institution Registration Page (IRP) to provide basic informat ion about institutional characteristics. Finally, institutional coordinators will be asked to provide electronic enrollment lists of all students enrolled during the academic year. Institutions will be offered two methods for providing their enrollment lis ts: 1. Upload encrypted student enrollment list files to the project’s secure website using a login ID and strong password provided by RTI , or 2. Email an appropriately encrypted list file directly to RTI . Based on NPSAS:12 full
- scale and NPSAS:16 field test res ults , we expect that most NPSAS:16 enrollment lists will be uploaded to the project website, and very few enrollment lists will be sent via e
- mail. **Table 2. Ma** **ximum estimated burden on institutio**  **ns for the NPSA S:16**  **full scale enrollment list collection**  Da ta collection activity Institution sample Expected

eligible institutions Number of

responding institutions Percent

expected response rate Average time

burden per response ( mins ) Range of

response times ( mins ) Total time

burden (hours) NPSAS:16 full scale study Eligibility screening calls 1 , 690 1 , 640 1 , 690 100 4.8 1.8 - 6.0 135 Institutional registration page † 1 , 640 1 , 394 85 4.8 3.0 - 6.6 112 Institutional enrollment lists † 1 , 640 1 , 394 85 165 .0 60.0 - 360.0 3,834 **Full scale Institutional total**  **1 ,**  **690 (**  **4 ,**  **478 responses)**  **4,081** † Not applicable.11

**13. Estimates of Cost**  There are no additional costs to the respondents . **14. Costs to Federal Government**  A summary of estimated costs to the federal government for NPSAS:16 are shown in table 3 . **Table 3. Individual and total costs to**  **N CES for the**  **NPSA S:16**  **field test and full -** **scale implementations** NPSAS:16 implementations Costs to NCES Field test NCES Salaries and expenses $62,370 Contract costs 7,173,724 To tal 7,236,094 Full - scale study NCES Salaries and expenses 197,739 Contract costs 13,574,629 To tal 13,772,368 Total costs NCES Salaries and expenses 260,109 Contract costs 20,748,353 To tal $21,008,462 NOTE: Costs presented here do not include base fee. Included in the cost estimates are staff time, reproduction, postage, and telephone costs associated with the management, data collection, analysis, and reporting for which clearance is requested (although this request is for full scale institution contacting and enrollment li st collection only, the costs shown are for the entire full
scale data collection , including institution and student data collection efforts. Table 4 provides a more detailed breakdown of contract costs . **15. Reasons for Changes in Response Burden and Costs**  The apparent decrease in burden is due to the fact that the last approval was for the NPSAS:16 institution and student field test collections, while this request is for the full scale data collection for institutions only. The burden for the full scale student data collection will be added in a submission in the fall 2015. **16. Publication Plans and Time Schedule**  The operational schedule for the NPSAS:16 full
- scale study is shown in table 5 . The formal contract for NPSAS:16 requires the following reports, publications, and other public information releases:  D escriptive summaries of significant findings for dissemination to a broad audience;  D etailed data file documentation describing all aspects of the full
- scale study design and data collection procedures , including an appendix summarizing the methodological findings from the field test;  C omplete data files and documentation for research data users in the form of both a restricted
- file; QuickStats, a public
- use data analysis system in which users create their own tables and charts using pre - defined categories from a subset of variables; and PowerStats, which allows users to create their own tables and charts using all of the variables, in addition to conducting regression analysis ;  S pecial tabulations of issues of interest to the higher education community, as determined by NCES. **17. Ap**  **proval to Not Display Expiration Date for OMB A**  **pproval** The expiration date for OMB approval of the information collection will be displayed on data collection instruments and materials. No special exception is being requested.12

**18. Exceptions to Certification for Paperwork Reduction A** **ct Submissions** There are no exceptions to the certification statement identified in the Certification for Paperwork Reduction Act Submissions of OMB Form 83
- I . **Table 4**  **. Contract costs for NPSA** **S:16** Study area and task Budgeted amount 110 Post award conference $25,400 120 Schedules 26,353 130 Monthly reports 215,474 140 Integrated monitoring system 544,143 150 Technical review panels 1,286,662 160 Mini - meetings 135,116 Standardized institution data collection 210 Task 2 Comparison Report 323,667 220 Institution Data Reporting System 358,575 Full - scale data collection 410 Sampling 474,362 420 OM B forms clearance 105,070 421 Instrument development 1,048,446 422 Training 406,704 423 Tracing 605,531 424 Data collection 4,432,465 425 Interview data processing 1,262,758 432 CPS file merge 50,053 433 NSLDS file merge 34,463 434 Other system file merge 218,940 435 Develop data collection materials 111,009 436 We ighting, imputation, and nonresponse bias analysis 212,304 437 Data disclosure 29,388 441 Enrollment list collection 698,939 442 Institution data collection 462,466 443 Institution data processing 759,727 Reporting 511 Report prospectus 57,125 512 Draft manuscript 245,997 513 Review- quality manuscript 151,531 514 Public - ready manuscript 90,942 515 Respond to professional judgment 19,789 610 Respond to information requests 564,165 620 Major IT data reporting 242,693 630 Ad hoc reports 111,926 **Table 5**  **.**

 **Operational schedule for NPSA** **S:16 NPSAS:16 activit**  **y Start date**  **End date** Full - scale study Contacts with institutions to request enrollment lists Oct. 1, 2015 Feb. 26 , 2016 Enrollment list collection Jan. 1 1, 2016 Jul. 10, 2016 Select student sample Jan. 1 8 , 2016 Ju n. 1 , 2016 Collect student data from institutional records Feb. 1, 2016 Sept. 30. 2016 Self - administered web - based data collection Feb. 1, 2016 Sept. 30, 2016 Conduct telephone interviews of students Feb. 22, 2016 Sept. 30, 2016 Process data, construct data files Jan. 22, 2016 Jun. 14, 2017 Prepare/update reports Aug. 1, 2016 July 31, 2018