## A Study of Implementation and Outcomes in Upward Bound and

**Other TRIO Program s**  **Part A**  **: Supporting**  **Statement for Paperwork Reduction Act Submission** October 12, 2012

Prepared for Institute of Education Sciences U.S. Department of Education Prepared b y Decision Information Resources, Inc. Abt Associates Contract Number: ED
- IES
- 10
- R
- 0015Page 2 

## Contents

**Part A :**  **Justification** A.1. Explanation of Circumstances That Make Collection of Data Necessary

.......................... 6 A.2. Purpose for Collecting the Information, How It Will Be Collected, b y Whom It Will Be Collected

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

................................ ........... 8 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. Pay ments to Respondents

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

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

................................ ................................ ...................... 10 A.12. Estimates of Respondent Burden

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

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

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

................................ ................................ ................................ . 12 A.16. Time Schedule, Publication, and Anal ys is P lan

................................ ............................. 12 A.17. Display

of Expiration Date for OMB Approval

................................ ............................. 15 A.18. Exceptions to the Certification Statement

................................ ................................ ....... 15Page 3

**List of Tables** Table 1. Estimated Total Reporting Burden for Survey Respondents.............................11 Table 2. Anticipated Sequence of Data

- Collection and Reporting Activities.....................13 Table 3. Example

—Grantees by Selected Organizational Characteristics........................15 Table 4. Example

—

Approaches to Providing Academic Tutoring, b y Lo cation of Project.................................................................................................16 Table 5. Approaches to Providing College Entrance Exam Preparation, by Ty pe of Host Institution.............................................................................17 Table 6. Use of Advanced Technology for Delivering Program Components ..................18Page 4

**INTRODUCTION** This clearance request is submitted to the Office of Management and Budget ( OMB ) in support of data collection and anal ys is planned as part of A Study of Implementation and Outcomes of Upward Bound and Other TRIO Programs, sponsored b y the Institute of Education Sciences (IES) at the U.S. Department of Education (ED). This request is a resubmissi on on behalf of this project, after ED and OMB determined that an earlier plan for the study was not feasible. 1 **Overview of the Upward Bound Program** The Upward Bound (UB) Program, the oldest and largest of the federal TRIO programs , was initiated under Title IV of the Higher Education Act of 1965 as a pre - college program designed to help economically disadvantaged high school students (low

- income and/or first

generation college going) prepare for, enter, and succeed in postsecondary education

. With grant awards approximating $5,000 per student per ye ar, Upward Bound provides an intensive set of services. In the most recent (FY 2012) grant competition, ED sought to make the provision of those services more productive and cost effective by incentivizing p roject applicants to propose new delivery

methods and approaches that could reduce the cost per student without sacrificing implementation quality . Awards were made to 820 Upward Bound grantees totaling $268.2 million to serve more than 62,500 students

. The structure of Upward Bound projects is well established, defined largel y by specific statutory language prescribing project and student eligibility and the services offered. Students usually enter the program while in the ninth or tenth grade. Altho ugh students may participate in Upward Bound through the summer following twelfth grade (for three to four years total), participants spend an average of 21 months in the program. 2 Upward Bound projects are generall y operated b y two - or four

- year colleges . Projects must offer academic instruction as well as college counseling, mentoring, and other support services. In addition to regularl y scheduled meetings throughout the school ye ar, projects also offer an intensive instructional program that meets dail y for about six weeks during the summer. Upward Bound projects may provide additional services or supports to students , beyond the set of required core activities

. Currently , very

little is known about the intensity , duration, and mix of services , or how they are delivered , particularl y for FY 2012 grantees that may have changed implementation strategies under the new grant r equirements **Overview of the Study and the Role of the Proposed Data Collection** The Study of Implementation and Outcomes of Upward Bound and Other TRIO Programs was awarded in August 2010 as a first step towards launching a congressionally mandate study . T he 2008 reauthorization of the Higher Education Act (HEA) required ED to conduct a study that would identify particular institutio nal, community , and program or project

1 The original OMB submission (1850

-NEW (04471)), for site visits to 20 Upward Bound grantees, was submitted on 4/20/11 and later withdrawn. 2 U.S. Department of Education, Office of the Under Secretary, Policy and Program Studies Service, The Impacts of Regular Upward Bound: Results from the Third Follow

- Up Data Collection , Washington, D.C., 2004.Page 5

practices that are effective in improving Upward Bound student outcomes ( 20 U.S.C. 1070a
- 1 8 ) (see Appendix A)

. However, the law also prohibit ed an y study of a TRIO program that would require grantees to “recruit addi tional students beyond those that the program or project would normally recruit” or that would result “in the denial of services for an eligible student under the program or project.” These prohibitions were initially seen as eliminating the possibility o f conducting a randomized control trial within the Upward Bound program. The new contract was intended to explore possible designs for and the feasibility of conducting a study

of the effectiveness of one or more promising practices in Upward Bound. D esi gn work completed highlighted the weaknesses of popular , program - supported study approaches such as matching grantees on certain project characteristics and then assessing variation in student outcomes that could be attributed to differences in project imp lementation. 3 In consultation with OMB in summer 2011, ED moved forward to investigate the options for testing out certain “enhanced” practices or alternative strategies for implementing core components of Upward Bound using a randomized control trial. The data collection for which we are now seeking OMB approval is part of that effort. 4 The survey

of FY 2012 Upward Bound grantee project directors has two objectives:
1. **To help**  **identify one or more**  **strateg ies**  **to test as part of a random assignment demon**  **stration .**  One challenge in pursuing a rigorous study of promising practices in Upward Bound , given that it is a service

- rich program , is understanding how (not just whether) projects implement core components , where gaps in services might exist, and the prevalence of both the implementation approaches and gaps. In order not to violate the statutory

prohibition against denying regular Upward Bound services to student participants, we have to ensure that any promising strategy we evaluate is not already wi dely implemented but ye t is sufficiently attractive to Upward Bound projects to allow us to recruit grantees not already implementing the strategy to participate in a research demonstration involving random assignment.
2. **To provide new and up**  **- to**  **- date**  **information about the services and strategies that**  **Upward Bound grantee**  **s implement ,**  **particularly under the new**  **grant productivity**  **requirements .**  The last survey of program implementation was conducted in 1997 5 and the program office has an interest in ob taining information that is more current

. The

3 Th is type of quasi

- experimental study wo uld n ot yield reliable or conclusive results because of the inability to fully isolate the effects of any particular implementation strategies. Upward Bound projects differ in the students they serve, the relationship between the grantee “host institution” and its participating high schools, the level of external resources, and many other factors in addition to their approaches to implementing core components and services. To measure the effects of implementing a particular (potentially promising) approach to a UB component an evaluation wo uld need to statistically “control for” everything else that might differ among projects and influence outcomes; there would inevitably be unknown or not easily measured factors that could have a powerful effect on outcomes. 4 IES has also awarded a separate contract with an option to conduct an RCT of a promising practice within Upward Bound, once such a practice or strategy can be identified under the current contract. 5 Moore, Mary T. “The National Evaluation of Upward Bou nd: A 1990's View of Upward Bound Programs Offered, Students Served, and Operational Issues.” Washington, D.C.: U.S. Department of Education, 1997.Page 6

survey will attempt to capture approaches to program services and supports that participants experience and which may improve their prospects of successfully competing high school and entering and/or college. The survey is designed to address the following research questions:

 How are the key components and service areas implemented within Upward Bound ?

 What is the prevalence of specific strategies or approaches for implementing s ervice areas or program compone nts across grantee projects ?

 Where are there gaps in services that might be linked to improving student outcomes?

 What strategies or approaches may be amenable to testing through an experimental design to measure impact on student outcomes?
The project director survey will be administered to all 820 regular Upward Bound grantees in the spring of 2013. Because of the need to collect information on how services are implemented, the instrument is detailed and designed to take approximately 40 minutes to c omplete. We are soliciting input from the TRIO community and other college access experts to improve the instrument during the public comment period. The results of the data collection will be tabulated and released in a summary report. **A.1. Explain the**  **circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.**  **Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collec**  **tion of information.** This survey

is necessary

in order to prepare for and conduct the congressionally

mandated study

of promising practices in Upward Bound (see Appendix A), given the comprehensiveness of required services under the program and the statut ory prohibitions on changing recruitment of student applicants or denyingregular Upward Bound services to participants. These factors make identifying practices or strategies that can be evaluated rigorousl y more dependent on obtaining grantee informatio n on existing implementation approaches or gaps in service. The timing of the survey (approximately

10 months after grant award) is designed to ensure that Upward Bound projects already know their implementation strategies so that any demonstration of pro mising practices is clearl y an “add

- on” to what projects that participate in the demonstration intended to offer.Page 7

**A.2. Indicate how, by whom, and for what purpose the information is to be used. Except**  **for a new collection, indicate the actual use the ag ency has made of the information**  **received from the current collection.**
**a. How and By Whom the Data Will be Collected**  In formation for the Upward Bound implementation study survey be collected and anal yz ed b y a contractor selected through a competitive pro curement. The survey of project directors is expected to take approximately 40 minutes to administer and will be fielded with all 820 Upward Bound grantees. A draft of the letter inviting project directors to complete the survey is included in Appendix B and will be sent in spring 2013

. The survey will not collect personall y identifiable information other than the names and contact information for UB project directors, which are publicly available on the UB websites and in project directories. All data for this study

will be collected through a web

- based survey , although provision will be made for alternative hard

- cop y and phone completion, if necessary . Our approach to implementing web

- based survey s will help to ensure we attain the high response rate d esired to minimize non

- response bias. To obtain high response rates, the study team will employ a number of features in the design and administration of the survey that have been demonstrated to be effective in web

- based survey s. These features include:

 clearl y identifying the survey sponsorship and support by key stakeholders  providing for multiple modes for completion

—including the web, hard

- copy , and by phone, if the respondent desires,  use of reminder follow

- up calls 6 Ongoing data files will be extracted for anal ys is throughout the survey period to ensure responses are being appropriately captured, regardless of mode. **b. Purpose for Collecting the Information**  The survey

of project directors is necessary to obtain current and detailed information on the approaches and strategies used to implement core components of Upward Bound , information that w ill inform efforts to fulfill the congressionally mandated study

of promising practices within the UB program. T he UB Annual Performance Reports (APRs) submitted by project directors to ED are insufficientl y detailed to capture meaningful variations in grantee strategies for implementing program components or to help categorize practices that could , in turn, measure relationships between implementation strategies and student outcomes.

6 Millar, Morgan M. and Donald Dillman. “Improving Response to Web and Mixed

- Mode Surveys.” Public Opinion Quarterly. Volume 7 5 , Number 2, Summer 20 11; Heerwegh, Dirk. “Effects of Personal Salutations in Email Invitations to Participate in a Web Survey. Public Opinion Quarterly. Volume 69 , Number 4 , Winter 2005. http://survey.sesrc.wsu.edu/dillman/papers/websurveyppr.pdf , accessed 6 November 2002.Page 8

**A.3. Describe whether, and to what extent, the collection of information involves the use**  **of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g.,**  **permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also**  **describe any consideration of using information technology to reduce burden.** The survey

instrument for this study has been designed t o be administered through a web platform; however, provision will be made for alternative modes of completion (i.e. telephone or mail). This will allow respondents the opportunity to complete the surve y at a convenient time and pace, and reduce s response b urden through use of appropriate skip logic

. A web

- based survey also reduces time and human error associated with manual data entry by allows respondent

- entered data to be directl y loaded into a data file

. **A.4. Describe efforts to identify duplication. S**  **how specifically why any similar information already available cannot be used or modified for use for the purposes**  **described in Item 2 above.** The information to be gathered by this data collection does not currentl y exist in a sy stematic format. Similar i nformation has not been collected concerning UB grantees for over 15 years. **A.5. If the collection of information impacts small businesses or other small entities,**  **describe any methods used to minimize burden.** No small businesses will be involved as res pondents. However, some grantees may be considered small entities. To minimize burden on these small entities, ED will use a web

- based survey to allow responde nts to complete the survey at a time and pace most convenient for them. **A.6. Describe the cons**  **equences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal**  **obstacles to reducing burden.** This submission includes a survey that will be conducted only one time during the full study period and will collect information not otherwise available to the study . The survey of Upward Bound Project directors will provide new and current information abo ut the services and strategies grantees implement and identify potential promising practices. Not collecting this information from grantees would prevent ED from fulfilling the mandate to conduct a rigorous study of promising practices in Upward Bound. **A .7.**  **Explain any s pecial**  **c ircumstances**  **r equiring**  **c ollection of**  **i nformation in a**  **m anner**  **i nconsistent with Section 1320.5(d)(2) of the Code of Federal Regulations**  **.** There are no special circumstances associated with this data collection. **A.8. If applicable**  **, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d),** Page 9

**soliciting comments on the information collection prior to submission to OMB. Summarize public comments rece**  **ived in response to that notice and describe actions taken by the agency in response to these comments**  In accordance 5 CFR 1320.8 (d) , a 60
- day Federal Register was published on XX , 201 2 announcing the agency ’s intention to request an OMB review of data c ollection activities and providing a 60
- day

period for public comments. After the agency revises the OMB package in response to public comments, a second notice will be published in the Federal Register and another 30

- day

period will be provided for publi c comments. **A.9. Explain any decision to provide any payment or gift to respondents, other than**  **remuneration of contractors or grantees.** No pay ments will be made to respondents as they are all current grantees receiving ED funding

. **A.10. Describe**  **any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.**  ED, its study

contractor (Decision Information Resources, Inc.), and other parties involved in the study

will follow the policies and procedures required by the Education Sciences Reform Act of 2002 , Title I, Part E, Section 183 . The a ct requires, “All col lection, maintenance, use, and wi d e 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 Ge neral Education Provision Act (20 U.S.C. 1232g, 1232h).” These citations refer to the Privacy Act, the Famil y Educational Rights and Privacy Act, and the Protection of Pupil Rights Amendment. Other than the names and contact information for the project directors , no data collected for this survey will contain personall y identifiable information. UB project director names and contact information are already publicl yavailable on UB websites and directories of UB projects , however, n o names and contact inform ation will be released as part of the study

. ED, the survey

contractor (Decision Information Resources, Inc.), and other parties involved in the study

will protect the confidentiality of all information collected for the study and will use it for researc h purposes only . The following safeguards will be put in place:

 Respondents will be assured that confidentiality will be maintained, except as required b y law.  Id entifying information about respondents (e.g., respondent name, address, and telephone numbe r) will not be entered into the analy sis data file, and will only be kept in hard cop y in a locked filing cabinet.  A fax machine used to send or receive documents that contain confidential information will be kept in a locked file room, accessible only to study team members.  Confidential materials will be printed on a printer located in a limited access file room. When printing documents that contain confidential information from sharedPage 10 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 b y type of respondent or for subgroups of interest. No reports will identify individual respondents or local agencies.  Access to the sample files wil l be limited to authorized study staff onl y; no others will be authorized such access.  All members of the study team will be briefed regarding confidentiality of the data.  A control sy stem will be in place, beginning at sample selection, to monitor the st atus and whereabouts of all data collection instruments during transfer, processing, coding, and data entry . This includes sign

- in/sign

- out sheets and the hand

- carrying of documents by authorized project staff only

.  All data will be stored in secure areas accessible only to authorized staff members. Computer
- generated output containing identifiable information will be maintained under the same conditions.  When any

hard copies containing confidential information are no longer needed, they will be shredded. In addition, the following language will be included in the recruitment letters: As required by the policies and procedures of 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 individuals and institutions and will not associate responses with a specific UB grantee, school district, school, or person. We will not provide information that i dentifies grantee respondents to anyone outside the study team, except as required by law. Any willful disclosure of such information for nonstatistical purposes, without the informed consent of the respondent, is a class E felony. **A.11. Provide addition**  **al justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are**  **commonly considered private. This justification should include the reasons why the agency considers the questions**  **necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is**  **requested, and any steps to be taken to obtain their consent.** The re are no questions of a sensitive nature included on the data

- collection instruments for this study

. **A.12. Provide estimates of the hour burden of the collection of information.**  **The statement should:** 

**• Indicate the number of respondents, frequency of response, annual hour burden,**  **and an explanation of how th e burden was estimated. Unless directed to do so,**  **agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential** Page 11

**respondents is desirable. If the hour burde n on respondents is expected to vary**  **widely because of differences in activity, size, or complexity,** show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
**•** If this **request** for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83

-I.
• Provide **estimates** of annualized cost to respondents for t he hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be in cluded in Item 13. All of the hour and cost burden for this study will fall on Upward Bound project directors who will be asked to complete the survey

. The burden estimate s assume 100% of respondents complete the survey . Non
- response would reduce the burden estimate accordingl y. **Estimated Hour Burden for Survey Respondents.**  The planned study includes one survey of Upward Bound project directors. The same survey instrument will be used for all respondents. The survey will be administered to all 820 regu lar Upward Bound grantees. The time to complete the survey is estimated to be 0.67 hours Table 1 presents our total hour burden estimates for survey respondents. The total hour burden for survey

respondents is estimated to be 549 hours (820 respondents x 0.67 hours per respondent). Because this is a one

- time data

- collection effort, no separate estimate of annual burden is provided. **Table 1 . Estimated**  **Total Report** **ing Burden for Survey Respondents**
Respondents Number of

Respondents Frequency

of Collection Average

Time per Respondent Total

Hourly Burden Estimated

Hourly Wage * Estimated

Total Burden Project Director 820 1 .67 hours 549 hours $ 32.65 $17,9 25 **TOTAL 820**  **549 $17,9**  **25**

* 2010 Statistical Abstract of the U.S.

—Table 630. Mean Hourly Earnings and Weekly Hours by Selected Characteristics: 2007. The rate used here for the project director reflects the hourly wage for a manager in state and local governments, which may be higher than the wages for a UB project director. **Estimate d**  **of the Cost Burden to Survey**  **Respondents .**  As shown in Table 1, the estimated total hour burden for survey respondents is 549 hours (820 respondents x 0.67 hours per respondent). The cost burden per hour for the survey reflects the hourly

wage ($32.65) for a manager in state and local governments. Multiplying the total number of hour burden by the average hourl y wage yields a total cost estimate of $17,925. In addition to their time respondents incur no other direct monetary costs
. Table 1 shows the total cost burden estimate for the survey data collection.Page 12

**A.1 3**  **. Provide an estimate for the total annual cost burden to respondents or**  **record**   ** keepers** **resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).**  N o annualized capital

- startup costs or ongoing operation and maintenance costs are associated with collecting the information. **A.14. P**  **rovide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification**  **of hours, operational expenses (such as equipment, overhead, printing, and support staff),**  **and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items**  **12, 13, and 14 in a single table.** The total cost to the federal government for the Implementation and Outcomes Study of Upward Bound and Other TRIO Programs i s $ 1,495,180
. This total includes the substantial work that has already been conducted between 2010 and 2012 through this contract in examining the feasibility

of alternative experimental and quasi

- experimental design options and data sources for an evaluation of UB, anal yz ing data from UB Annual Performance Reports and grant applications, and preparing materials for a set of qualitative case study visits. T he annual cost for activities being conducted in FY 2012
- 2013 , which includes design, implementation , and initial design o f the project director survey , including obtaining input from expert reviewers and stakeholders, is $ 508,878
. **A.15. Explain the reasons for any program changes or adjustments re**  **ported in Items 13 or 14 of the OMB Form 83**  **- I (these references will change when the Information**  **Collection Submission Worksheet is finalized).** This is a new data collection request. **A.16. For collections of information whose results will be published,**  **outline plans for tabulation and publication. Address any complex analytical techniques that will be**  **used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, public**  **ation dates, and other actions.**  This section outlines the time schedule for activities and deliverables and presents anal ys is plans for the project director survey data

. **Time Schedule for Activities and Deliverables** The schedule shown in Table 2 lists the sequence of activities required to conduct the information

- collection activities described in this submission and includes key dates for activities related to respondent notification , data collection, anal ys is, and reporting.Page 13

**Table 2**  **. Anticipated Seq uence of**  **Data -**  **Collection and Reporting**  **Activities Activity**  **Expected Dates** Administration of survey 4 /1 5 /2013

- 6/15/13 Internal m emo summarizing in i tial findings
– to inform development of research demonstration on promising practices 6/30/13
Release of report 4/30/ 1 4 **Analysis Plans for Project Director Survey Data**  The focus of the anal ys is will be to describe implementation strategies used for key components of the UB program by current grantees. We will group implementation by categories of grantees defined b y key UB organizational characteristics

—including type of host institution, location of grantee services, and number of target schools. D escriptive analy sis will examine the approaches to components offered overall and by categories o f grantees , illuminating possible relationship s between service strategies and organizational characteristics

. Examples of the se ty pes of tabulations are provided in Tables 3
- 5
. The anal yt ic approach is straightforward and will include tabulation of means and distributions. Because we have sampled the universe of grantees and expect a 100 percent or near 100 percent response, it is not appropriate to compare approaches using traditional t

- tests. **Table 3**  **. Example** 

**— Grantees**  **by Selected**  **Organizational C haracteristics**  **Study Sites Number of**  **Grantees Percent of** 

**Grantees Location**  Urban Suburban Rural **Type of Host**  **Institution** Tw o - Year Four
- Year **Number of Active Target Schools** 1 2
- 3 4
- 5 More than 5Page 14

**Table 4**  **. Example** 

**—**

**Approaches to Provid**  **ing Academic**  **Tutoring ,**  **by Location**  **UB Project Provision of Academic Tutoring,** 

**by Location of**  **Project Approaches to Providing Academic**  **Tutoring Urban**  **% (n) Suburban** 

**% (n) Rural** 

**% (n)** Provide group tutoring Provide one - on - one tutoring Use on - line tutoring resources Level of Participation in Tutoring Services % of projects in which tutoring required of som e students **Frequency of Tutoring** Offered daily Offered once weekly Offered less than weekly **Methods Used to Determine Tutorial Offerings to Students**  Use school records Use teacher referrals Student assessments Parents or students express need **Characteristics of Tutorial Staff** Use paid UB staff Use volunteers Use paid college students from host institutionPage 15

**Table 5**  **. Approaches to Providing College Entrance Exam Preparation**  **, by**  **Type of Host Institution**  **UB Project Provision of College Entrance Exam Preparation, by**  **Host Institution Type Two**  **- Year**  **% (n) Four**  **- Year** 

**% (n) College Exam (**  **SAT -**  **ACT )**  **Prep Services** Provide group preparation assistance Provide one
- on - one preparation assistance Use on
- line preparation assistance Use third
- party assistance (e.g., Princeton Review) **Level of Participation in College Exam Prep Services**  % of projects in which participation required of students % requiring 9 th grade students to participate % requiring 10 th grade students to participate % requiring 10 th grade students to participate % requiring 10 th grade students to participate **Intensity of College Exam Prep Offerings** Mean number of hours of exam prep offered per student per year **Characteristics of Exam Prep Staff** Use paid UB staff Use volunteers Use paid college students from host institution Use third party group to provide service

**A.17. If seeking approval to not display the expiration date for**  **OMB approval of the information collection, explain the reasons that display would be inappropriate.**  All data

- collection instruments and associated forms will display the expiration date for OMB approval. **A.18. Explain each exception to the**  **certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83**  **- I.**  **Again, the reference will change when the Information Collection Submission Worksheet is finalized.**  No exception is requested or nee ded.