### January **30, 2013** 

# Private School Universe Survey **(PSS) August 2013**  **— July 2016** 

**Supporting Statement**

**Part A Request for OMB Review**  **OMB# 1850 -**  **0 641**  **v. 5** 

Submitted by **National Center for Education Statistics**

**U.S. Department of Education**1 S UPPORTING STATEMENT TABLE OF CONTENTS **A. JUSTIFICATION ................................**  **................................ ................................**  **.................... 2**  Al. Why

I s This Information Needed? ................................ ................................ ................... 2 A2. Purpose and Uses of the Data ................................ ................................ .......................... 2 A3. Appropriate Use of Information Technology ................................ ................................ ... 3 A4. Efforts to I dentify

Duplication ................................ ................................ ......................... 3 A5. Small Business or Entities ................................ ................................ ............................... 3 A6. Frequency

of Data Collection ................................ ................................ .......................... 3 A7. Special Circumstances of Data Collection ................................ ................................ ....... 3 A8. Consultations Outside the Agency ................................ ................................ ................... 3 A9. Pay ment or Gift s to Respondents ................................ ................................ ..................... 5 A10. Assurance of Confidentiality ................................ ................................ ........................... 5 A11. Need for the Use of Sensitive Questions ................................ ................................ ......... 5 A12. Estimates of Information Collection Burden ................................ ................................ ... 5 A13. Capital and Operating Costs to Respondents ................................ ................................ ... 6 A14. Estimates of Cost to the Federal Government ................................ ................................ . 7 A15. Changes in Burden ................................ ................................ ................................ ........... 7 A16. Publication Plans/Time Schedule ................................ ................................ .................... 7 A17. Request Not to Display Expiration Date ................................ ................................ .......... 8 A18. Exceptions to the Certifications ................................ ................................ ....................... 8 **APPENDIX A. STATE LIST REQUEST L**  **ETTER APPENDIX B. ASSOCIAT**  **ION LIST REQUEST LET TER**  **APPENDIX C. TELEPHON E SCRIPT**  **APPENDIX D. PSS QUES TIONNAIRE**  **APPENDIX E. EXAMPLES OF TABLE SHELLS** 2 Request for Clearance for the Private School Universe Survey This is a request for cle arance to conduct the 2013 - 14 and 2015 - 16 Privat e School Universe Survey (PSS) data collections and the 201 5 - 1 6 PSS frame - development activities . **A. JUSTIFICA** 

**TION** Al. Wh y Is This Information Needed? The National Center for Education Statistics (NCES), within the U.S. Department of Education, conduct s PSS, a national survey

of private elementary

and secondary

schools. The PSS is designed to collect biennial data on the total number of private schools, teachers, and students; and create an NCES universe f rame of private schools that then serve as a sampling frame for NCES surveys of private schools. This survey is an ongoing project to improve NCES universe and sample data on private schools. Since 1980, NCES has annually collected descriptive universe data on the number of public school teachers, students, and high school graduates through the NCES Common Core of Data (CCD) for the public schools. Private schools represent approximately 25 percent of all elementary and secondary schools in the United Stat es and enroll an estimated 10 percent of the nation’s elementary and secondary students. With increasing policy concern about choice and alternatives in education, the interest and need for data on private education has also increased. NCES has recognized this need to assure that the collection of data on private schools be comparable to public school data. In1989, NCES established an Interagency Agreement with the U.S. Census Bureau to collect and process private school data. The PSS was conducted in 198 9 - 90, 1991 - 92, 1993 - 94, 1995 - 96, 1997 - 98, 1999 - 2000, 2001 - 02, 2003 - 04, 2005 - 06, 2007 - 08, and 2009 - 10 and th os e data have been released. The 20 11 - 1 2 PSS data have been collected and are scheduled to be released in April 2013 . NCES is authorized to conduct this survey

under the Education Sciences Reform Act of 2002 ( ESRA: 20 U.S.C., § 9543 ). A2. Purpose and Uses of the Data NCES has conducted several national sample surveys of private elementary and secondary

schools beginning in the 1970s. Recently, Schoo ls and Staffing Surveys (SASS) for 1987 - 88, 1990 - 91, 1993 - 94, 1999 - 2000, 2003 - 04, 2007 - 08 , and 2011 - 12 provided estimates of the numbers and characteristics of private schools, teachers, and students for comparison among private schools and with public sch ools. Even w ith successive administrations of SASS providing detailed trend data on a sample of private schools 1 , there is a need for biennial universe data on a limited number of key statistics and a need to update the private school sampling frame for births/deaths of private schools every several years. Except for previous PSS, the sampling frames available for private school surveys have not been timely nor have they

provided complete coverage. Commercial lists, such as those developed by QED, are not complete and lack sufficient detail on school characteristics to select samples according to NCES specifications. Lists maintained by organizations of private schools are also incomplete because they only contain listings of their member schools. The purpo ses of this project are, therefore, to: collect biennial

1 SASS is scheduled to end with the 2011 - 12 collection ; it is unclear at the present time whether its replacement , the National Teacher and Principal Survey , will have a private school component .3

data on the total number of private schools, teachers, and students; and create an NCES universe frame of private schools that can serve as a sampling frame for NCES surveys of private schools. A3. Appropriate Use of Information Technology Imaging and CATI As in the 2003 - 04, 2005 - 06, 2007 - 08, 2009 - 10 , and 20 11 - 1 2 PSS collections, the data from all 2013 - 14 and 2015 - 16 PSS paper questionnaires will be imaged and stored electronically . And, as in all previous PSS collections, CATIfollow - up will be used in 201 3 - 14 and 2015 - 16 for mail/internet nonrespondents (an estimated 2 0 percent of all respon ses will be collected by CATI). Furthermore, the 201 3 - 1 4 and 2015 - 16 PSS, like the 2011 - 12, 2009 - 10 , and 20 05 - 06 PSS, will offer an internet response option to most schools (Amish and Mennonite schools will not be offered an internet response option). A4. Efforts to Identify Duplication One of the criteria for PSS is to collect only data that are not availabl e elsewhere. The Elementary

/Secondary

Sample Survey

Studies Program reviewed existing private school data collection efforts and found no other private school data collection effort existing or planned that will update the private school universe. A5. Sma ll Business or Entities The PSS collects data from elementary and secondary

private schools. Private schools are small entities. The respondent burden is minimal because of the limited questionnaire size (22 items) and because the data that are being coll ected are readily available from the administrative files of most private elementary and secondary

schools. A6. Frequency of Data Collection The current plan is to continue to conduct the PSS for the entire private school universe biennially . I f the PSS were collected less frequently, NCES would be forced to use sampling frames with significantly poorer coverage for its surveys of private schools. A7. Special Circumstances of Data Collection There are no circumstances that will require special data coll ection efforts. A8. Consultations Outside the Agency Key offices inside the U.S. Department of Education have reviewed the draft survey . Prior to the first PSS in 1989 - 90, NCES discussed its data collection plans with a number of private school associati ons. Representatives from the following private school associations participated in these initial discussions. Association Contact Accelerated Christian Education Dr. Donald Howard Agudath I srael of America Rabbi Morton Avigdor American Association of Christian Schools Dr. Robert Stashesky4

American Montessori Society Ms. Bretta Weiss Association of Christian Schools International Dr. John Holmes Association of Evangelical Lutheran Churches Mr. Kretzman Association of Military

Colleges and Schools Lt . General Willard W. Scott Christian Schools International Dr. Sheri D. Haan Council for American Private Education Ms. Joyce McCray Evangelical Lutheran Church in America Mrs. Billie Navarro Friends Council on Education Ms. Kaye Edstene General Conference of Seventh Day Adventists Dr. G. L. Plubell Jesuit Secondary

Education Association Rev. Carl E. Meirose Lutheran Church, Missouri Sy nod Mr. Carl Moser National Association of Episcopal Schools Ms. Ann Gordon National Association of Independent Schools Dr. Peter Relic National Association of Private Schools for Ms. Sherry L . Kolbe Exceptional Children National Catholic Educational Association Mr. Frederick Brigham National Coalition of Alternative Community Schools Ms. Pat Montgomery National Independent Private School Association Ms. Caroly n Crider National Society

of Hebrew Day

Schools Rabbi Fishman Oral Roberts Educational Fellowship Dr. David Hand Solomon Schechter Day

Schools Mr. Meir Efrati U.S. Catholic Conference Father William Davis Wisconsin Evangelical Lutheran Sy nod Dr. Daniel Schmeling Since the 1989 - 90 PSS, private school group meetings have been held annually with affiliation representatives to inform them of the PSS status. The last meeting was held in November 2012; the following private school groups were represented at the meeting: Agud ath Is rael of America David Tanenbaum American Association of Christian Schools Courtney Holloway Association of Christian Schools International George Tryfiates Association of Christian Teachers and Schools R. J. Nelson Council for American Private Education Joseph McTighe National Association of Independent Schools Amada Torres Hilary L aMonte Martha Galindo National Catholic Educational Association Dale McDonald National Christian School Association Philip Patterson Oral Roberts University

Education Fellowship Donnie Peal Southern Baptist Association of Christian Schools Edward Gamb le U.S. Conference of Catholic Bishops Suzanne Bellenoit Wisconsin Evangelical L utheran Sy

nod Schools Scott Gostchock5

A9. Payment or Gifts to Respondents Not applicable. A10. Assurance of Confidentiality The law does not require disclosure protection of institutions, such as schools; therefore, no assurance of confidenti ally

is provided to respondents . A11. Need for the Use of Sensitive Questions The questions contained in this survey

—grade levels taught, length of the school day and school year, religious orientation, ty

pe of school, number of teachers, enrollment, race/ethnicity of students, and number of graduates

—are not co nsidered to be sensitive. A12. Estimates of Information Collection Burden 201 3 - 1 4 PSS Approximately

8,000 screener calls will be made to institutions discovered in the area- frame operation (see Part B . 2) to determine their eligibility for the PSS. The average length of these calls is 3 minutes, resulting in 400 hours of respondent burden for the area - frame screener operation. 2 Survey questionnaires will be sent to all of the cases on the 201 3 - 1 4 universe. The requested data can be easily obtained from s chool records. The average completion time will be 20 minutes (based on the 20 11 - 12 PSS experience) per respondent (2 7 , 0 00), for a total of 9 , 000 hours of questionnaire respondent burden. The total respondent burden for the 201 3 - 1 5 PSS, frame development (400) plus questionnaire ( 9 , 00 0) , is 9, 400 hours **Table of 2013 -**  **14 PSS Data Collection Instruments** Document Ty pe Instrument File Respondents Respon ses Burden Time per Resp onse Available

Electronically Percent Responding

Electronically Electronic Capability Total Burden Hours Private Schools Telephone Script Appendix C 8,000 8,000 3 min no 0% Telephone o nly 400 PSS Questionnaire Appendix D 27,000 27,000 20 min yes 18% Both electronic and p aper v ersions 9,000 Total Burden 27,000 35 ,000 9,400 The standard NCES procedure for estimating costs to school staff is to multiply the estimated total survey reporting hours ( 9 , 40 0 ) by the average salary

of school employees (estimated to be $20.00 per hour). Following these conventions, the “cost” to the respondents is estimated to be about $1 8 8 , 0 0 0 for the 201 3 - 1 4 PSS. 201 5 - 1 6 PSS During the development of the list - frame portion of the 201 5 - 1 6 PSS universe ( see Part B.2 ), lists of private schools will be requested and received from approximately 100 stat e agencies and private school associations. It is estimated that each list response will take an hour, resulting in 100 hours of respondent burden. Approximately 6 ,600 screener calls will be made to institutions discovered in the list - frame

2 The respondent burden for the 2013 - 14 PSS list - frame operation is included in the July 2010 - June 2013 PSS clearance.6

operation to determine their eligibility for the PSS. The average length of these calls is 3 minutes, resulting in 330 hours of respondent burden for the list - frame screener operation. Total response burden for 201 5 - 1 6 PSS list - frame development activities is 430 hours. Approximately

8,000 screener calls will be made to institutions discovered in the area- frame operation to determine their eligibility for the PSS. The average length of these calls is 3 minutes, resulting in 400 hours of respondent burden for the area - frame screener operation. The total response burden for 201 3 - 1 4 PSS frame development is 830 hours. Survey questionnaires will be sent to all of the cases on the 2015 - 16 universe. 3 The requested data can be easily obtained from school records. The average co mpletion time will be 20 minutes (based on the 2011 - 12 PSS experience) per respondent (27,000), for a total of 9 , 00 0 hours of questionnaire respondent burden. The total respondent burden for the 2015 - 16 PSS, frame development ( 830 ) plus questionnaire ( 9 , 00 0 ) , is (9, 830 ) hours **Table of 201 5**  **- 1**  **6 PSS Data Collection Instruments**  Document Ty pe Instrument File Respondents Respon ses Burden Time per Response Available

Electronically Percent Responding

Electronically Electronic Capability Total Burden Hours State A gencies (Education, Social Services, Child Care) School List Request Letter Appendix A 70 70 60 min no 0.9 Both electronic and p aper v ersions 70 Private School Association School List Request Letter Appendix B 30 30 60 min no 0.5 Both electronic and p aper v ersions 30 Private School Telephone Script Appendix C 14 , 600 14 , 600 3 min no 0 Telephone o nly 730 PSS Questionnaire Appendix D 27 , 000 27 , 000 20 min yes 0.18 Both electronic and p aper v ersions 9 , 000 Total Burden Hours 27 ,1 00 41 , 7 00 9 , 830 The standard NCES procedure for estimating costs to school staff is to multiply the estimated total survey reporting hours ( 9, 830 ) by the average salary

of school employees (estimated to be $21.00 per hour). Following these conventions, the “cost” to the respondents is estimated to be about $ 20 6 , 430 for the 201 5 - 1 6 PSS. The average annual burden for the 2013 - 14 and 2015 - 16 collections over the three year period is : **18 ,0**  **34 respondents**  **25,567 responses**  **6,410 burden hours**  A13. Capital and Operating Costs to Respondents Respondents will not incur any costs other than their time to respond.

3 The PSS and the SASS were originally scheduled to both be collected during 2015 - 16. In the past, the private schools in the SASS sample would receive the SASS private school questionnaire only and not the PSS questionnaire. PSS records for these schools were creat ed electronically from the SASS private school file. The respondent burden hours for these schools were included in the SASS burden hours. Since SASS is scheduled to end with the 2011 - 12 SASS collection and it is unclear at the present time whether its rep lacement, the National Teacher and Principal Survey, will have a private school questionnaire, the 2015 - 16 PSS burden includes the entire data collection burden hours associated with the 2015 - 16 universe.7

A14. Estimates of Cost to the Federal Government NCES estimates that the total federal cost for the 2013 - 14 PSS is approximately **$3, 650**  **,000** ($ 132 , 019 in FY 2012 , $1, 511 , 668 in FY 2013 , $ 1,7 37 , 142 in FY 2014 , and $269,171 in FY 2015 ) , and for the 2015 - 16 PSS is approximately **$3,905,000** ($141,234 in FY 2014, $1,617,182 in FY 2015, $1,858,394 in FY 2016, and $288,190 in FY 17) . This estimate was compiled from individual estimates developed within each U.S. Census Bureau division involved in the survey . Estimates were based on the universe size, the length of the questionnaire, and required data processing. Administrative overhead, design, printing, and mailing cos ts were included. Thus the average annual cost for the 2013 - 14 and 2015 - 16 collections over the three year period is **$2,518,333** . A15. Changes in Burden The burden associated with the 201 3 - 1 4 and 2015 - 16 PSS (9, 400 and 9,830 hours respectively ) is somewhat greater than that of the 20 11 - 1 2 PSS ( 9 , 12 7 hours). This increase is the net result of a number of factors. The 2013 - 14 PSS list - frame development burden was included in the last PSS clearance (2011 - 2013) and is not included in this clearance. The estimated number of interviews i s increased from 26,200 (2011 - 12 PSS) to 27,000 (2013 - 14 and 2015 - 16 PSS) , reflecting both the inclusion of 3,000 schools that were included with the 2011 - 12 SASS collection burden and the reduction in the total number of priv ate schools that has been occurring since 2007. The estimated completion time for the PSS questionnaire is revised upward from 1 9 minutes (based on the 200 7 - 0 8 PSS) to 20 minutes (based on the 20 11 - 12 PSS). Additionally, because PSS is biannual, the last OMB 3 - ye ar clearance cycle (2010 - 13) encompassed only

one full scale data collection, while the cycle of this request (2013 - 2016) encompasses two full scale data collections. A16. Publication Plans/Time Schedule 201 3 - 1 4 PSS The first mailing of questio nnaires is scheduled for September 2 5 , 201 3 . A second mailout for schools that did not respond to the first mailout is scheduled for November 201 3 . Telephone follow - up for nonresponse will begin in January 201 4 . Personal visit follow - up for mail/internet n oninterviews and CATInoninterviews is scheduled for January 201 4 through May

201 4 . The 201 3 - 1 4 PSS survey

will be conducted according to the following time schedule: Conduct Screener Calls for Area - Frame Schools 9/ 3 /201 3 - 9/30/201 3 1st Survey

Mailout 9/2 5 /201 3 2nd Survey

Mailout 11/201 3 CATI/Field Followup 1/201 4 - 5/201 4 Check - in, Clerical Edit 9/201 3 - 5/201 4 Process Data 11/201 3 - 10/201 4 Final File 11/201 4 NCES Reports Results 4 /201 5 201 5 - 1 6 PSS The first mailing of questionnaires is scheduled for Septemb er 2015 . A second mailout for schools that did not respond to the first mailout is scheduled for November 2015. Telephone follow - up for8

nonresponse will begin in January 2016. Personal visit follow - up for mail/internet noninterviews and CATInoninterviews is scheduled for January 2016 through May

2016. The 2015 - 16 PSS survey

will be conducted according to the following time schedule: Request Private School Lists 8/ 1 /201 4 Conduct Screener Calls for Li st - Frame Schools 8/201 4 - 5/201 5 Conduct Screener Calls fo r Area - Frame Schools 9/201 5 - 9/201 5 1st Survey

Mailout 9/201 5 2nd Survey

Mailout 11/201 5 CATI/Field Followup 1/201 6 - 5/201 6 Check - in, Clerical Edit 9/201 5 - 5/201 6 Process Data 11/201 5 - 10/201 6 Final File 11/201 6 NCES Reports Results 4 /201 7 One of the purpose s of this survey is to produce descriptive statistics about the number of private schools, teachers, students, and high school graduates. Survey responses will be weighted to produce national estimates. Tabulations will be produced for each data item. Cros s tabulations of data items will be made with selected classification variables such as religious orientation (Catholic

— parochial, diocesan, private; other religious

—conservative Christian, affiliated, unaffiliated; nonsectarian

— regular, special emphasis, special education); size of student body (less than 50, 50 to 149, 150 to 299, 300 to 499, 500 to 749, 750 or more); and level of instruction (elementary, secondary, combined). See Appendix E for examples of table shells (for a more comprehensive set of ta bles see Characteristics of Private Schools in the United States: Results From the 2009 - 10 Private School Universe Survey, NCES 20 11 - 3 39, which can be accessed from the PSS web page at http://nces.ed.gov/surveys/pss). NCES will publish the 201 3 - 1 4 survey results in April 201 5 and the 2015 - 16 survey results in April 2017 . A17. Request Not to Display Expiration Date Not applicable. A18. Exceptions to the Certifications Not applicable.