# 2015 **- 16 NATIONAL POSTSECONDARY** 

**STUDENT AID STUDY (NPSAS:16) Field Test**  **Student Records Abstraction** 

**and Student Interview**  **Supporting Statement Part A**  **OMB # 1850 -**  **0666 v.**  **13**

Submitted by National Center for Education Statistics

U.S. Department of Education

**October 2014** 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 ................................ ................................ ................................ ................................ ............ 4 a. NPSAS:16 Purposes ................................ ................................ ................................ ................................ ....................... 4 b. NPSAS:16 Research and Policy Issues ................................ ................................ ................................ ....................... 4 c. Study Design for NPSAS:16 ................................ ................................ ................................ ................................ ......... 7 3. Use of Information Technology ................................ ................................ ................................ ................................ .......... 7 4. Efforts to Identify Duplication ................................ ................................ ................................ ................................ ............ 8 5. Method Used to Minimize Burden on Small Businesses ................................ ................................ ................................ 8 6. Frequency of Data Collection ................................ ................................ ................................ ................................ .............. 8 7. Special Circumstances of Data Collection ................................ ................................ ................................ ......................... 9 8. Consultants Outside the Agency ................................ ................................ ................................ ................................ ......... 9 9. Provision of Payments or Gifts to Respondents ................................ ................................ ................................ .............. 9 10. Assurance of Confidentiality ................................ ................................ ................................ ................................ .............. 10 11. Sensitive Questions ................................ ................................ ................................ ................................ .............................. 13 12. Estimates of Response Burden ................................ ................................ ................................ ................................ .......... 13 13. Estimates of Cost ................................ ................................ ................................ ................................ ................................ . 15 14. Costs to Federal Government ................................ ................................ ................................ ................................ ........... 15 15. Reasons for Changes in Response Burden and Costs ................................ ................................ ................................ ... 16 16. Publication Plans and Time Schedule ................................ ................................ ................................ ............................... 16 17. Approval to Not Display Expiration Date for OMB Approval ................................ ................................ .................. 17 18. Exceptions to Certification for Paperwork Reduction Act Submissions ................................ ................................ ... 17 **B. Collection of Information Employing Statistical Methods**  **C .**  **References** 

## Ap **pendixes** A. Technical Review Panel (TRP) Members B. Endorsing Associations for NPSAS:16 C. Confidentiality for Administrative Record Matching D. D ata S ecurity Language for Vendor C ontracts E . Previous Studies Based on NPSAS, B&B, and BPS Data F . Respondent Communication Materials

– Institutions and Students G . Student Records Instrument Facsimile H . Student Interview Facsimileiii 

## Tables Table 1. Chronology of NPSAS and its longitudinal components ................................ ................................ ...................... 3 Table 2. Maximum estimated burden on respondents for the NPSAS:16 data collections ................................ ........... 14 Table 3. Maximum estimated costs to respondents for the NPSAS:16 data collections ................................ ............... 14 Table 4. Individual and total costs to NCES for the NPSAS:16 field test and full

- scale implementations ................ 15 Table 5. Contract costs for NPSAS:16 ................................ ................................ ................................ ................................ ... 15 Table 6. Operational schedule for NPSAS:16 ................................ ................................ ................................ ....................... 171 

### A. **Justification 1.**  **Circumstances Making Collection of Information Necessary**  **a. Purpose of this Submission**  This document supports the clearance of selected materials and procedures for student records abstraction and interviewing for the field test of the 2015

- 16 National Postsecondary Student Aid Study (NPSAS:16). The NPSAS:16 field test institution sampling and contacting, and enrollment list collection was approved in July 2014. NPSAS :16 is being conducted by the National 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

- 007 0) , and subcontractors include Coffey Consulting; Hermes; HR Directions; KF orce Government Solutions, Inc.; Research Support Services; Shugoll Research; and Strategic Communications, Inc. Consultants are Dr. Sandy Baum , Dr. Stephen Porter, and Ms. Alisa Cunningham. This submission covers NPSAS:16 field test materials and pro cedures related to student record abstractions , student surveying, and matching data to administrative files . Following the field test study in 2015, NCES will provide the Office of Management and Budget (OMB) with a memorandum summarizing any changes planned for the full

- scale data collection, and a revised OMB package. The materials that will be used in the 2015

- 16 full scale study will be based upon the field test materials included in this submission. Additionally, this submission is designed to adequately justify the need for and overall practical utility of the full study and to present the overarching plan for all of the phases of the data collection, providing as much detail about the measures to be used as is available at the time of this submission. As part of this submission, NCES is publishing a notice in the Federal Register allowing first a 60

- and then a 30

- day public comment period. For the final proposal for the full study, after the field test, NCES will publish 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. NPSAS:16 is a nationally representative study of how students and their families finance education beyond high school. NPSAS was first 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 rec ently during the 2011

– 12 academic year. This submission is for the ninth cycle in the series that will be conducted during the 2015

– 16 academic year. NPSAS:16 also will serve as the base year data collection for the 201 6 B accalaureate and Beyond Longitudin al Study (B&B), a study of college graduates one year (B&B:16/17), four years (B&B:16/20), and up to ten years (B&B:16/26) following completion of 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 membership list of the Technical Review Panel (TRP) for the student data collection component of NPSAS:16 (appendix A);  A list of endorsing institutions and associations supporting NPSAS:16 (appendix B).  A description of the confidentiality procedures in place for the administrative record matching (appen dix C);2

 The data security language for vendor contracts (appendix D);  A list of p revious studies related to or based on data from NPSAS or its longitudinal spin

- offs (appendix E);  Contacting materials for institution staff providing student records and sample members selected for participation in the student survey (appendix F );  Facsimiles for the NPSAS:16 field test student records (appendix G ) and student interview and reinterview (appendix H) instruments ; and **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 Statistics, shall conduct, on a State

- by

- State basis, a survey of recipients of Federal student financial aid under subchapter IV of this chapter and part C of subchapter I of chapter 34 of title 42

— (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 burden 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 postseco ndary 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, gra duate, 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, N PSAS 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 (primarily vocational) not on a traditional calendar sy stem, 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 can be found at http://nces.ed.gov/surveys/npsas/ .3

Since its inception, the data collection techniques, sources, and sampling and weighting methods used for NPSAS have evolved to meet new demands 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 stude nts, 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 students, and adde d 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 separate sampling for all levels of the for

- profit sector: less

- than

- 2

-year, 2

-year, and 4

-year institution . In addition, NPSAS:12 was the first cycle to use current-year 12

- month institutional enrollment data to ensure more accurate poststratification (weighting) than using prior

-year enrollment data. **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 of students attending post secondary 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 students 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 y** **ear 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 BPS:96/11 * NPSAS:2000 B&B:2000/01 — — NPSAS:04 BPS:04/06 BPS:04/09 BPS:04/11 * 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. *Administrative data matching only. 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 ai d and student debt; 6. Access to graduate programs; and4

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 E for reference. **2. Purposes and Uses of the 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 financial aid, enrollment, demographic , and other information 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 o f their demographic characteristics, academic programs, types of institutions attended, attendance patterns, and employment. Demographic and enrollment data establish the appropriate context that allows researchers and policy analysts to address basic issu es about postsecondary affordability and the recipients of student financial assistance. These results are presented in two First Look reports and four Web Tables publications: an overview of student aid by institutional sector, a profile of undergraduates , a detailed description of undergraduate financing, and a profile of graduate students and the financing of their education beyond the bachelor’s degree. In addition, an undergraduate financing report describes the total price of attendance for undergraduates (tuition and fees plus non

- tuition expenses), the net price after grant aid, and the “out

- of

- pocket” net price (after all aid, including loans). The data can be used to calculate statistics with PowerStats and QuickStats, two web

- based software applic ations 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 o f 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 20 26. 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. 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 sourc e of data that could be used to support experimental research funded by NCER. Interested researchers will be asked to submit a proposal that details their experimental design and analysis plans. Upon grant review and approval, RTI will conduct any needed d ata collection and/or file

matching activities and deliver a restricted data file to NCES to provide to the grantee for analysis. More detail s about the NCER grant for analyses based on NPSAS will be provided in the full

- scale package for student data coll ection . **b. NPSA** **S:16 Research and Policy Issues**  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. The5

NPSAS:16 data will be used to address policy issues related to the changes in federal financial aid programs resulting from the anticipated reauthorization of the Higher Education Act. In addition, the NPSAS:16 field test may pilot new items in areas of interest to academic researchers, such as personality measures that previous studies have linked to academic outcomes, and will devote greater attention to measuring the experiences of graduate students. Some of the primary research and policy issues to be a ddressed through the use of NPSAS:16 data will likely be: (1) Student demographics;  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 th e largest proportions of low

-income, non

- traditional, and ethnic minority 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 programs;  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’ prim ary purposes for enrolling in postsecondary education and their educational goals? (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?6

 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 Post

- 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 proportions 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 ty pe 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) Stud ent 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 D irect (Stafford) loan amounts?  What is the difference in the proportion 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 private 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?  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 types of employment?  What proportion of graduate assistantships reduce or fully remit tuition and fees, provide a stipend for nontuition expenses, or both, and what are the average amounts of these assistantships? (7) Sources of funds;  What types of financial support are dependent students receiving from their parents?  What is the estimated proportion of students who might benefit from the federal education tax benefits (such as the American O pportunity and Lifetime Learning tax credits) based upon family income, tuition paid, and grant aid received?7

 What proportion of students are using novel education financing mechanisms such as crowdsourcing and human capital contracts? 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 p ublications listed in appendix E 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. **c. S**  **tudy Design for NPSA S:16**  Data for NPSAS:16 will be collected from both postsecondary institutions and students. The target population includes all students enrolled in a sample of institutions in a given academic year (2014

– 15 for the field test and 2015

– 1 6 for the full

- scale study). A stratified sample of students within the sampled institutions will be selected. Given the short time frame for the NPSAS:16 field test, institutions with continuous enrollment will be asked to include students enrolled only through March 31, instead of April 30, to expedite data collection. 1 In order to re

- evaluate the impact of the truncated enrollment period, i.e., April 30 instead of June 30, during the field test, we will request that the date first enrolled at the institution be included on the lists and that some field test institutions provide lists with students enrolled through the end of June. Using administrative and frame data from the lists, we will conduct a bias analysis to determine if there are differences between the May/June enrollees and all other students and will modify our approach for the full

scale list collection if this analysis shows that there are differences. I nstitutions will be asked to provide information from student financial aid records and other institutional sources. Much of the required student financial aid data contained in institutional records is also available in the Central Processing System (CPS), which houses and processes data contained in the Free Application f

or Federal Student Ai d (FAFSA) forms . These data will be obtained through file matching/downloading with this system. The process reduces the data collection burden on sampled institutions. As in NPSAS:12, institutions will be asked to verify institutional characteristics and financial aid program participation and to provide enrollment lists for sampling purposes. Data from students will be collected via a self

- administered survey on the Internet or through web

- based CATI. Additional data for the NPSAS:16 student sample will b e obtained from a variety of administrative data sources. These include , as described above, queries of CPS, plus the National Student Loan Data System (NSLDS) containing Pell loan and grant files, the National Student Clearinghouse (NSC), and vendors of national undergraduate, graduate, and professional student admission tests including ACT and SAT scores. A descript ion of the security procedures in place for the linkages to administrative data sources is provided in appendix C and the data security language for vendor contracts is presented in appendix D . **3. Use of Information Technology**  Both the institution and student websites for data collection will reside on NCES’ SSL

- encrypted servers. To improve the efficiency of the student interview, the NPSAS:16 field test will use web

- based questionnaires across two modes of data collection, self

- administered surveys and computer- assisted
1 All institutions will be asked to include students enrolled through April 30 in the full

- scale.8

telephone interviewing (CATI), and will be made mobile

- friendly to allow participants to complete the full survey on a tablet or smartphone. In the BPS:12/14 full

- scale data collection currently underway, 78.1 percent of interviews have been c ompleted online, with 39.4 percent of the mobile

- friendly abbreviated interviews completed on a mobile device . On a nightly basis, the data collection contractor, RTI , will download student record and interview data, in batches, to their Enhanced Security Network (ESN) via a secure web service. Once in the ESN, data will be cleaned and undergo quality analysis. **4. Efforts to Identify Duplication**  Efforts to identify duplication have included NCES consultations with other federal offices, such as the U.S. Department of Education’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, NCES 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 to be 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 duplicat ion, these consultations 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 other studies in the U.S duplicate the data produced by NPSAS. **5. Method Used to Minimize Burden on Small Businesses**  The student survey for NPSAS:16 does not involve small businesses or entities. However, for

- profit schools and other small public and private schools will be asked to provide student record data. To minimize burden on these institutions, NPSAS:16 will offer institutions a choice of several methods for submitting the requested data. An inst

itution may select the format (s) that it finds most convenient and least burdensome. Available methods include: (1) uploading an electronic file to the project’s secure web site; (2) downloading an Excel workbook from the project’s web site, then uploading the completed file to the site; (3) use of a web

based data entry interface. **6. Frequency** 

**of Data Collection** This cycle of NPSAS will take place 4 years after the last field test data collection. Large - scale and rapid changes in federal policy concerning pos tsecondary education, and particularly student aid , necessitate frequent studies. Eligibility restrictions change, 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 resulting level of their debt, data collections every 3 to 5 years are necessary. Repeated administrations of NPSAS are essential in helping predict future costs for financial aid as federal loan9

programs create continued obligations for the government, and are necessary because of the dynamic nature of the postsecondary environment. Effects of changes in federal policy and postsecondary education create an opportunity, as well as a need, for monitoring on a regular basis. Note that the last two President's budgets have included funding for more frequent data collections using administrative data but, thus far, those proposals have remained unfunded. **7. Special Circumstances of Data Collection**  No special circumstan ces 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 comment s relating to project activities, interim and final products, 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 issues in postsecondary education, including financial aid (a list of the TRP m embers is provided in appendix A ). Three technical review panel meetings have been held to inform the NPSAS:16 data collection. At least one additional meeting is planned for summer 2015 to discuss the results of the field test and review plans for the 2016 full

- scale study design. **9. Provision of Payments or Gifts to Respondents**  In an effort to maximize response rates, the use of incentives is proposed for two purposes

—to encourage early res ponse using the self

- administered web survey and to minimize nonresponse through refusal conversion. All cases will be offered a total incentive of up to $30, but the distribution of the amount will differ depending on the field test condition to which eac h sample member is randomly assigned .  The **Control Group** in Experiment 1 will be offered $30 , paid upon completion of the survey, by the sample member ’ s choice of check or PayPal , an online money transfer service .  **Treatment Group 1** of Experiment 1 will be asked to complete a 10 to 15 minute portion of the survey for a $15 incentive paid by their choice of either check or PayPal. At the completion of the first half of the survey, participants will be offered the opportunity to complete the remaining 10 to 15 minutes of the survey for another $15 incentive, payable either by check or PayPal.  **Treatment Group 2** of Experiment 1 will be asked to complete the same 10 to 15 minute portion of the survey described for Group 1, except Group 2 will be offered a $20 incentive paid by their choice of either check or PayPal. At the completion of the first half of the survey, Group 2 participants will be offered $10 to complete the remaining 10 to 15 minutes of the survey, payable either by check or PayPal. The Tests of Procedures and Methods section of this document (section B.4) discusses this experiment in more detail . In general, the use of incentives provides significant advantages to the government in terms of increased overall response rates, timely data collection, and reduction of nonresponse bias. The10

use of incentives can also result in decreased data collection costs since the large majority of interviews for which the incentives are paid are conducted on the web and before telephone interviewers b egin outbound calling, which is the more labor

-intensive and therefore costly phase of data collection of this type. **10. As**  **surance of Confidentiality** NCES assures participating individuals and institutions that all identifiable information collected under NPSA S 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 securit y and confidentiality protection procedures are in place to ensure that RTI and its subcontractors comply with all privacy requirements, including:  The Statement of Work of this contract;  Privacy Act of 1974 5 U.S.C. § 552(a);  The U.S. Department of Educat ion 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. To further ensure that confidentiality is appropriately maintained at all times, vendors who assist in locating and tracing sample members will be required to follow procedures that safeguard personally identifying information. RTI’s vendor contracts outline requirements for information security policies and assessments, security awareness training, physical and environmental security, monitoring, and access control. They also specify the means by which information may be transmitted between RTI and the contractor . RTI will also 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 Management 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 ac cess to individual identifiers; per sonnel 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 detailed 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, encrypt ion, and project file storage/archiving/destruction.11

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 using FIPS 140

- 2 validated encryption tools. Furthermore, the Department has established a policy regarding the personnel security screening 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 contra ct for 30 days or more. Among these requirements are that each person working on the contract must be assigned 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 Security Screening.” Depending on the risk level assigned to each person’s position, a follow

- up background investigation by the Department will occur. Study notification materials sent to institutions for student records and to students being surveyed will describe the voluntary nature of NPSAS:16 and convey the extent to which respondent identifiers and all responses will be kept confidential. Similarly, the scripts to be read by telephone staff will be very specific in the assurances made to respondents and contacts. Contacting materials are presented in appendix F . The following confidentiality language is provided in the study brochure that is supplied to all sample members: The 2015

- 16 National Postsecondary Student Aid Study is conducted under the authority of the Higher Education Opportunity Act (HEOA) of 2008 (20 U.S.C. § 1015) and the Education Sciences Reform Act (ESRA) of 2002 (20 U.S.C. § 95 43) which authorize NCES to collect and disseminate information about education in the United States. NCES is required to follow strict procedures to protect personal information in the collection, reporting, and publication of data. All individually ident ifiable information supplied by individuals or institutions 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 (20 U.S.C. § 9573). Data security procedures for NP SAS:16 are reviewed and approved by NCES data security staff. Your answers are secured behind firewalls and are encrypted during internet transmission using Secure Sockets Layer (SSL) protocol. All data entry modules are password protected and require the user to log in before accessing confidential data. Project staff is subject to large fines or imprisonment if individual responses are disclosed. 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 the 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;12

(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 organiz

ation 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 demographic and enrollment data to establish the appropriate context. The resultant data set allows research and policy analysts to address basic issue s about the affordability of postsecondary education and the effectiveness of the existing financial aid programs. 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 § 9 9.31 (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 tho ugh 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 e mphasized 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 members, 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 concerning 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 . S tudents13

generally tend not to be a very reliable source of information about the amounts or timing of grants and loans they have received. This administrative record data is accurate and much easier to obtain than obtaining the same data by administering a questionnaire. **11. Sensitive Questions**  The s tudent interview collects information about earnings, assets, and marital and dependency status es . Regulations governing the administration of these questions require (a) clear documentation of the need for such information as it relates to the primary purpose of the study, and (b) provisions to clearly inform sample members of the voluntary nature of participation in the study, as well as assurances that their responses will be treated confidentially. Financial data related to earnings and assets, as well as marital and dependency statuses are key items used in calculating need for financial aid, parental contributions, and financial aid awards. Consequently, the data elements are critical to the conduct of policy

- related analyses and to the modeling and projection of the effects of federal program changes on students and on program costs. Several procedures have been implemented (see section A.10) to provide assurances to sample members about the voluntary nature of participation in the study as well as the confidentiality provisions for survey responses. Social Security Numbers (SSN s) will be needed to 1) conduct file matches to administrative records and 2) maintain the sample for the B&B longitudinal study. File matching to administrative records is a cru cial element of the NPSAS study and would not be possible without the collection of SSNs. Data obtained from file matching will both minimize respondent burden and increase data quality. **12. Estimates of Response Burden**  Projected estimates for response burden and costs for NPSAS:16 are based on experiences from prior rounds of NPSAS. Two data collection activities will take place: (1) student record collection from eligible institutions that provided enrollment lists (approved in July 2014) and (2) student inte rviews. The respective burden estimates for each data collection activity are provided in table 2. Estimated costs to respondents for participating in the NPSAS:16 field test and full

- scale studies is provided in table 3. **Student record collection.** Based o n results from the NPSAS: 12 full

- scale study, about 25 percent of schools are expected to provide programmer

- created electronic data files to the contractor, resulting in an average estimated response burden of ab out 18 hours. The remaining 75 percent is expected to enter some portion of the requested information themselves at 25 hours per response (on average). This distribution of responses results in an estimated average of 22 hours per institution response for the full

- scale study. The estimated burden for field test institutional data collection is lower (approximately 13 hours) due to the smaller sample size for each institution. A facsimile of the student records instrument is provided in appendix G . **Student interviews.** Although a majority of the data elements to be used in NPSAS:1 6 appeared in the previously approved NPSAS:12 and NPSAS: 08 (the last NPSAS study to include a B&B cohort) studies, new items w

ill be included in NPSAS:16 (a f acsimile of the student interview, with re -interview items identi fied, is presented in appendix H). With the addition of the new items, burden for the field test interview is estimated to be about 30 minutes . We expect the interview to be shortened and streamlined following the field test, resulting in a lower estimate of approximately 25 minutes for completion of the full

- scale interview.14

**Table 2. Ma** **ximum estimated burden on respondents for the NPSA S:16 data collections**  **Data collection activity Sample**  **Expected eligible**  **Expected**

**number of respondents**  **Expected**

**response rate**  **(percent) Av**  **erage time**

**burden per response**  **Range of**

**response times Total time**  **burden (hours)**  **NPSA S:16 Field Test**  **Institutional Collection** 1 Eligibility screening calls 300 290 300 † 0.08 hrs. 2 to 6 min. 24 Institutional registration page † 290 247* 85 0.08 hrs. 3 to 7 min. 20 Institutional enrollment lists † 290 247* 85 2.75 hrs. 1 to 6 hrs. 680

**Student Collection** Student record collection 2 247 150 3 141* 94 13.0 hrs. 1 to 40 hrs. 1,833 Student list analysis 97 4 97 83* 85 2.8 hrs. 1 to 6 hrs. 232 Student interview 4,511 4,286 3,000 70 30 min. 20 min. to 1 hr. 1,500 Student re - interview 1,600 1,600 800* 50 10 min. 10 to 15 min. 133 **Field Test Total 3,300**  **( 4,818**  **responses) 4,422**  **NPSA S:16 Full**  **- scale Study**  **Institutional Collection** Eligibility screening calls 2,000 1,980 2 , 000 † 0.08 hrs. 2 to 6 min. 1 60 Institutional registration page † 1,980 1,683 * 85 0.08 hrs. 3 to 7 min. 135 Institutional enrollment lists † 1,980 1,683 * 85 2.75 hrs. 1 to 6 hrs. 4,628

**Student Collection** Student record collection 2 1,683 1,683 1,616 * 96 22.2 hrs. 1 to 40 hrs. 35,875 Student interview 126,316 120,000 84,000 70 25 min. 15 min. to 1 hr. 35,000 **Full -**  **scale T**

**otal 8**  **6 ,**  **000 (**  **90,9 8**  **2 responses)**  **7 5**  **, 798**  † Not applicable. * Duplicative counts of respondents, but not of responses. 1 The Institutional Collection burden was approved I July 2014. 2 “Sample” is the number of institutions that provided enrollment lists for student sampling with an average of 30 students expected per institution. 3 In the interest of time, field test student records will be obtained from the first 150 eligible institutions providing data. 4 The starting sample is the difference between the sample size for the student record collection and the number of eligible institutions selected. **Table 3. Ma** **ximum estimated burden time**  **costs to respondents for the NPSA S:16 data collections**  **NPSA S:16 Field Test**  **Institutional Collection** Eligibility screening calls 0.08 hrs 24 $38 1 $909 Institutional registration page 0.08 hrs 20 38 758 Institutional enrollment lists 2.75 hrs 680 38 25,765 **Student Collection** Student record collection 13.0 hrs 1,833 38 69,452 Student list analysis 2.8 hrs 228 38 8,639 Student interview 30.0 min 1,500 18 2 27,060 Student re - interview 10 min 133 18 2,399 **To tal**  **4,422 $134,983**  **NPSA S:16 Full**  **- scale Study**  **Institutional Collection** Eligibility screening calls 0.08 hrs 160 $38 6,062 Institutional registration page 0.08 hrs 135 38 5,115 Institutional enrollment lists 2.75 hrs 4,628 38 175,355 **Student Collection** Student record collection 22.2 hrs 35,875 38 1,359,304 Student interview 25.0 min 35,000 18 631,400 **To tal**  **75,798 $**  **2,177,236** 1 The total cost to respondents for institution data collection is based on the estimated response burden (hours) multiplied by $37.89, which includes average data analyst and associated computer costs for running programs to extract data. 2 The total est imated cost to respondents for student data collection is based on the estimated response burden (hours) multiplied by $18.04 , which was obtained by taking the average of the median weekly earnings of full - time wage and salary workers among high school gra duates with no college and individuals with some college or an associate’s degree. (Table 5, http://www.bls.gov/news.release/pdf/wkyeng.pdf .15

**13. Estimates of Cost**  There are no capital, startup, or operating costs to institutions or students for participation in the project. No equipment, printing, or postage charges will be incurred. **14. Costs to Federal Government**  Estimated costs to the federal government for NPSAS:16, shown in table 4, are categorize d by field test, full

- scale study, and total costs. Included in the contract estimates are staff time, reproduction, postage, and telephone costs associated with the management, data collection, analysis, and reporting for which clearance is requested (the costs shown here are for the full study, including institution and student data collection efforts). Table 5 provides a more detailed breakdown of contract costs. **Table 4**  **. Individual and total costs to**  **N CES for the NPSA** **S:16 field test and full -** **scale imple mentations**  **NPSA S: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. **Table 5**  **. Contract costs for NPSAS: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 **Field test data collection**  310 Sampling 379,416 320 OMB forms clearance 141,586 321 Instrument development 1,776,265 322 Training 336,001 323 Tracing 99,365 324 Student data collection 738,821 325 Student data processing 489,743 332 CPS file merge 19,479 333 NSLDS file merge 11,573 334 Other system file merge 73,373 335 Develop data collection materials 161,337 340 Methodology memorandum 202,96116

**Study area and task**  **Budgeted amount** 351 Enrollment list collection 612,974 352 Institution data collection 155,653 353 Institution data processing 237,622 **Full -** **scale data collection** 410 Sampling 474,362 420 OMB 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 **Total $20,748,353**  **15. Reasons for Changes in Response Burden and Costs**  This submission includes estimated response burden for field test student and institution data collections and, as such, is higher than the previously approved burden for the institution data collection only. **16. Publication Plans and Time Schedule**  The operational schedule for the NPSAS:16 field test and full

- scale study is shown in table 6 . The for mal contract for NPSAS:16 requires the following reports, publications , and other public infor mation releases:  Descriptive summaries of significant findings for diss emination to a broad audience;  Detailed data file documentation describing all aspects ofthe full

- scale study design and data collection procedures , including an appendix summarizing the methodological findings from the field test;  Complete 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 ;  Special tabulations of issues of interest to the higher education community, as determined by NCES.17

**Table 6**  **. Operational schedule for**  **NPSA S:16**  **NPSAS:16 activit y**  **Start date End date**  Field test Contacts with institutions to request enrollment lists Sept. 15, 2014 Feb. 3, 2015 Enrollment list collection Jan. 29, 2015 Jul. 31, 2015 Select student sample 1 Jan. 30, 2015 Ma y 14, 2015 Collect student data from institution records Mar. 3 , 2015 Jun. 30, 2015 Self - administered web - based data collection Mar. 3 , 2015 Jun. 30, 2015 Conduct telephone interviews of students Mar. 10 , 2015 Jun. 30, 2015 Process data, construct data files Mar. 2 , 2015 Aug. 31, 2015 Prepare/update field test reports Ma y 4, 2015 Dec 18, 2015 Full - scale study Contacts with institutions to request enrollment lists Oct. 1, 2015 Feb. 26, 2016 Enrollment list collection Jan. 11, 2016 Jul. 10, 2016 Select student sample Jan. 18, 2016 Jun. 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 1 Student samples will be selected from lists received by May 8, 2015 and the remaining lists will be used for a methodological test (see section B2 for more details). **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 collect ion instruments , including the student and institution websites . No special exception is being requested. **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.