SUPPORTING	STATEMENT	A:

REQUEST	FOR	CLEARANCE	OF	INFORMATION	

COLLECTION	FORMS	FOR

“Understanding	the	Impact	of	Providing	

Information	to	Parents	about	the	Role	of	Algebra	

II:	An	Opportunistic	Study”

January 2014

Submitted to: Submitted by:

U.S. Department of Education SEDL

Institute of Education Sciences 4700 Mueller Blvd.

555 New Jersey Ave. NW, Rm. 308 Austin, TX 78723

Washington, DC 20208 Phone: (800) 476-6861

4700 Mueller Blvd. Austin, TX 78723

800-476-6861

www.relsouthwest.org

This publication was prepared for the Institute of Education Sciences (IES) under contract ED-IES-12-C-00012 by 

Regional Educational Laboratory Southwest, administered by SEDL. The content of the publication does not 

necessarily reflect the views or policies of IES or the U.S. Department of Education, nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. government. The publication is in the public 

domain. Authorization to reproduce in whole or in part for educational purposes is granted.
Contents

Introduction ..................................................................................................................................................4

A. Justification...............................................................................................................................................6

1. Circumstances Necessitating the Data Collection................................................................................6

2. How, by Whom, and for What Purpose Information Is to Be Used...................................................... 9

3. Use of Automated, Electronic, Mechanical, or Other Technological Collection Techniques.............11

4. Efforts to Avoid Duplication of Effort..................................................................................................12

5. Sensitivity to Burden on Small Entities...............................................................................................12

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is 

Conducted Less Frequently Than Proposed............................................................................................13

7. Special Circumstances.........................................................................................................................13

8. Federal Register Announcement and Consultation............................................................................13

Unresolved Issues...............................................................................................................................15

9. Payment or Gift to Respondents.........................................................................................................15

10. Data Confidentiality ..........................................................................................................................15

11. Additional Justification for Sensitive Questions ...............................................................................17

12. Estimates of Hour Burden.................................................................................................................17

13. Estimate of Total Annual Cost Burden to Respondents or Record-Keepers.....................................20

14. Estimates of Annualized Cost to the Federal Government...............................................................20

15. Reasons for Program Changes or Adjustments................................................................................20

16. Plan for Tabulation and Publication and Schedule for Project.........................................................21

17. Approval Not to Display the Expiration Date for OMB Approval......................................................22

18. Exception to the Certification Statement .........................................................................................22

References ..................................................................................................................................................23

Attachment A-1. Information Materials (Intervention)..............................................................................25

Attachment A-2. School Principal Email .....................................................................................................26

Attachment A-3. School Principal Follow-up Email ....................................................................................27

Attachment A-4. School Principal Telephone Call Script ............................................................................28

Attachment A-5. School Mailing Verification Telephone Script .................................................................29

Attachment A-6. Student Records Data......................................................................................................30

Attachment A-7. IRB Approval....................................................................................................................31

Attachment A-8. Educational Sciences Reform Act (ESRA) ........................................................................32

Attachment A-9. Federal Register Notices..................................................................................................33
Attachment A-10. Confidentiality Form and Affidavits ..............................................................................34

Attachment A-11. Technical Working Group Suggestions..........................................................................35

Attachment A-12. School Agreement to Participate Form.........................................................................36
Introduction

The U.S. Department of Education (ED) requests clearance for data collection under the Office 

of Management and Budget (OMB) clearance agreement (OMB number [IES to complete]) for 

activities related to the Regional Educational Laboratory (REL) Program. ED, in consultation with 

SEDL, intends to conduct a timely, policy relevant opportunistic experiment to determine if 

directly providing parents/guardians, prior to students’ selection of their courses, with 

information on the importance of completing algebra II for college access and success has an 

impact on the percentage of students who enroll in and complete algebra II by the end of their 

junior year.

In 2013, the governor of Texas signed House Bill (HB) 5—the Foundation High School Program—

into law. HB changed the high school graduation requirements and reduced the number of 

required state secondary school exams for public high school students in Texas. Prior to 

enactment of HB 5, high school students were required take four courses each in English, 

mathematics (including algebra II), science, and social studies—earning the credits they needed 

to be admitted to most state universities and colleges. Now, only one of the three new 

graduation plans1, created for the Foundation High School Program requires completion of 

algebra II in order to graduate. Despite the change in high school graduation requirements, the 

public universities in Texas will still require students to have completed algebra I, geometry, 

and algebra II in order to gain admission

Thus, a relevant question is whether providing parents/guardians with information about the 

importance of completing algebra II will help prevent students who aspire to postsecondary 

degrees from opting to skip algebra II in high school. This study builds on research being 

conducted in a companion study that investigates the trends in the percentage of students in a 

school who complete algebra II by the end of their junior year for the graduating classes of 

2009-10 through 2016-17. 

The results of this study will provide Texas Education Agency (TEA) and the Texas Higher 

Education Coordinating Board (THECB) with information about the role that information 

dissemination can play in influencing students’ course selection and completion. Information 

from this study will provide TEA with valuable information that will inform their attempts to 

stem the number of students who wish to go on to postsecondary education, but may not be 

aware of the importance completing algebra II has toward this goal. The intervention is 

relatively inexpensive, so if it is successful, it would demonstrate the benefit of low-cost 

interventions for influencing student course selection. TEA will be able to use this information 

 

1

The STEM endorsement included in the Foundation plus Endorsement Plan also requires completion of algebra II.
to answer questions about changes in course taking patterns and course failure rates that may 

arise from parents, education practitioners and administrators, policymakers, and researchers. 

It will also allow them to respond to inquiries regarding any variation in how districts responded 

to the HB 5 graduation requirements.

Additionally, if the results of the study show that schools in which students’ parents were 

provided with information about the role of algebra II in college access and success have higher 

algebra II completion rates, TEA could recommend that districts conduct an information 

campaign similar to this one. The Texas Association for School Administrators has already 

expressed an interest in providing the materials to its members—all school principals in Texas. 

Similarly, if this study shows positive results, TEA could produce materials for districts to 

disseminate to parents when statewide policy changes occur. This would allow for a clear and 

consistent message that is currently lacking, as schools and districts must create their own 

materials based on their own interpretations of the policy. 

Finally, results of our study will provide evidence to other states about the impact of providing 

parents/guardians with information about course completion. Due to the size and demographic 

makeup, many states look to Texas for guidance when making decisions about implementing 

statewide policies and programs. The findings of this study should be of particular interest to 

those states. 

OMB approval is being requested to recruit public high schools in Texas to participate in this 

study, as well as to collect extant student data records from TEA.

This study will address the following research questions: 

Confirmatory Research Questions

1. Does providing information about the role of algebra II in college access and success

to the parents/guardians of students entering grade 9 after the enactment of House 

Bill 5 have an impact on:

a. The percentage of students in a school who enroll in algebra II by the end of 

their junior year?

b. The percentage of students in a school who complete algebra II by the end of 

their junior year?
Exploratory Research Questions

2. Are there differential impacts of providing information about the role of algebra II in 

college access and success on students’ algebra II enrollment for:

a. Schools with a high percentage of minority students? 

b. Schools with a high percentage of low-income students?

c. Schools with a high percentage of low-achieving students?

3. Are there differential impacts of providing information about the role of algebra II in 

college access and success on students’ algebra II completion for:

a. Schools with a high percentage of minority students? 

b. Schools with a high percentage of low-income students?

c. Schools with a high percentage of low-achieving students?

4. To what extent are schools implementing the intervention with fidelity?

Data collection for this project consists of recruitment activities (e.g., telephone calls, email 

messages) and collection of extant data files from TEA. Specifically, in this OMB clearance 

package, ED is requesting clearance for the following data collection approach:

 Recruitment activities, including telephone calls and email messages, targeted at public 

school districts and public high schools in Texas

 Verification of dissemination of study materials to parents 

 Extant data collection consisting of student records data to be obtained from the Texas 

Education Agency

ED believes that the data collections for which clearance is being requested represent the bare

minimum necessary to determine if providing parents/guardians, prior to students’ selection of 

their courses, with information on the importance of completing algebra II for college access 

and success has an impact on the percentage of students who enroll in and complete algebra II 

by the end of their junior year.

A. Justification

1. Circumstances Necessitating the Data Collection

In June 2013, Texas Governor Rick Perry signed House Bill (HB) 5—the Foundation High School 

Program—into law, which changed high school graduation requirements and reduced the 
number of required state secondary school exams in the state. HB 5 also grants the Texas State 

Board of Education (SBOE) decision-making authority on a number of other graduation-related 

issues. Prior to HB 5, Texas students could choose between two graduation plans: 

recommended and distinguished, with special provisions given for students to drop down to a 

minimum plan.2In both the recommended and distinguished plans, students were required to 

take four courses each in English, mathematics (including algebra II), science, and social 

studies—earning the credits they needed to be admitted to most state universities and 

colleges. 

With the enactment of HB 5, these two high school graduation plans were replaced with three 

new graduation plans: foundation, foundation plus endorsement3, and foundation plus 

distinguished. The foundation plan was crafted to give students who want to go directly into 

career and technical fields the flexibility to take more classes focused on their interests, instead 

of college preparation classes. Under the foundation plan, the number of credits required to 

graduate has been reduced from 26 to 22, and students are required to complete only three 

courses each in science, social studies, and mathematics. The foundation plus endorsement 

plan requires students to continue to earn 26 credits to graduate. Students selecting this plan 

must continue to complete four courses each in English, mathematics, and science; however, 

the mathematics courses do not have to include algebra II, with the exception of the STEM 

endorsement.4 Only students completing the foundation plus distinguished plan and the 

foundation plus STEM endorsement plan will continue to be required to complete four courses 

each in English, science, and mathematics, including algebra II—the course requirements for 

admission to most state four-year colleges and universities. 

In response, the SBOE has opted to change the Texas 10 percent rule, which offers admission to 

state-funded universities to all Texas high school students who graduate in the top 10 percent 

of their class, to only include students who graduate in the top ten percent of their class and 

complete the foundation plus distinguished plan beginning with the 2014–15 incoming cohort 

of grade 9 students. 

 

2

Only students meeting strict criteria were able to select the minimum plan, and a waiver acknowledging 

understanding of the Texas Minimum Graduation Plan had to be signed by a student’s parent or guardian.

2

The endorsements include science, technology, engineering, and mathematics (STEM); business and industry; 

public services; arts and humanities; and multidisciplinary studies.

3

The endorsements include science, technology, engineering, and mathematics (STEM); business and industry; 

public services; arts and humanities; and multidisciplinary studies.

4

A student may earn a STEM endorsement by completing foundation and general endorsement requirements 

including Algebra II, chemistry, physics, a coherent sequence of four or more credits in Career and Technical 

Education (CTE) that consist of at least two courses in the same career cluster including at least one advanced CTE 

course which includes any course that is the third or high course in a sequence, and a coherent sequence of four 

credits in computer science selected from the approved list. 
In addition, the public universities in Texas will still require students to have completed algebra 

I, geometry, and algebra II in order to gain admission, despite the disparity between some of 

the new graduation plans and admission requirements to state four-year colleges. Without 

information about the alignment between high school graduation requirements and college 

entrance requirements, parents may not be able to help their children make informed choices. 

This is particularly true for low-income and minority parents, whose children are most likely to 

be influenced by graduation requirements. Research has shown that these students are the 

most likely to respond to changes in graduation requirements, as they are the most likely to 

complete only the minimum graduation requirements (Chaney, Burgdorf, & Atash, 1997; 

Domina & Saldana, 2011; Saw & Broda, 2012; Schiller & Muller, 2003). As such, removing the 

algebra II graduation requirement for all high school students may affect some students’ 

eligibility for admission to state four-year colleges and universities. 

This study will investigate the impact of providing parents/guardians with information about 

the role of algebra II in college access and success. To do so, ED’s contractor will utilize an RCT 

in which the treatment schools provide parents/guardians of students with information about 

the role of algebra II in college access and success, while control schools continue business-asusual. The study will utilize extant student- and school-level data collected and archived in the 

statewide longitudinal data system maintained by TEA.

The study will follow the grade 9 students who begin high school in study schools during the 

2014–15 school year—the first cohort of students required to graduate under the state’s new 

diploma plans—through the end of grade 11. All grade 9 students, including special education 

student and English learners, who enroll in algebra I in study schools during their freshman year 

will be included in the study. Data analyses for this study will consist of a confirmatory analysis

and a set of exploratory analyses. The confirmatory analysis will examine the impact of 

providing parents/guardians with information about the role of algebra II in college access and 

success on algebra II course enrollment and completion by the end of junior year. The 

exploratory analyses will investigate differences in the effect of providing information about the 

role of algebra II for college access and success on students’ mathematics course completion for 

various subgroups. Informational materials will be mailed to parents of students in treatment 

schools during January and February 2015. The timing of the mailing is intended to coincide 

with when parents and their students select junior year courses—late February through early 

March. Extant data from the Texas Education Agency will be used to answer all research 

questions. 

The data burden timeline is shown in Table 2. 
Table 2. Data Burden Timeline

Data Collection Purpose

Requesting 

OMB 

Clearance?

Oct /Dec

2015

Jan/Feb

2016 July 2017

School recruitment

 Obtain consent from schools to 

participate in the study

Yes

X

School mailing 

verification  Implementation fidelity assessment

Yes X

Extant school and 

student data files

from the Texas 

Education Agency

 Student mathematics course 

enrollment, completion, and failure 

data

 Student background characteristics

 Description of Texas public high 

schools

Yes X X

2. How, by Whom, and for What Purpose Information Is to Be Used

ED’s contractor for REL Southwest will analyze the data to be collected through this study using 

statistical models and procedures that are preapproved by the Institute of Education Sciences 

(IES). The contractor will then summarize the findings in a report that will undergo review for 

quality and relevance by the National Center for Education Evaluation and Regional Assistance’s 

(NCEE’s) external review contractor. After the report has undergone IES review, findings will be 

presented to TEA (the primary audience) and published through IES for educators and 

education researchers (secondary audience).

To provide this information to the primary audience and the secondary audience, ED’s 

contractor is requesting OMB clearance to perform the three types of data burden activities 

listed in Table 2.

1. School recruitment. In order to recruit high schools to participate in this study, ED’s 

contractor will send email messages to all principals and conduct telephone calls 

with select principals from public high schools in Texas. Starting in fall 2015, ED’s 

contractor will begin recruiting high schools to participate in the study. 

Recruitment will be conducted via email and telephone. Around the third week of 

October, ED’s contractor will send an email to all high school principals in the state 
introducing the study and inviting them to participate (see attachment A-2). The 

emails will outline the goals of the study, the content of the informational materials, 

and the school’s role in information dissemination if randomized into the treatment 

condition. Principals will be made aware that this study is a randomized controlled 

trial (RCT) and that only half of participating schools will receive the informational 

materials and be involved in information dissemination initially; however, they will 

also be informed that their schools will receive the materials, if desired, after the 

conclusion of the study—the 2017-18 school year. Interested principals will be 

directed to contact REL Southwest for additional information. A follow-up email will 

be sent to all non-responding principals one week after the initial email (see 

attachment A-3). A second follow-up email will be sent the following week to all 

non-responding principals. One week after distribution of the second follow-up 

email, if enough schools have not agree to participate in the study, REL Southwest 

will begin conducting telephone recruiting calls. The REL Southwest researcher will 

ensure that principals understand the nature of the study and the responsibilities of 

participating schools (see attachment A-4). Once principals have agreed to 

participate in the study, they will be asked to sign a memorandum of 

understanding/consent form indicating that their school agrees to participate in the 

study (see attachment A-12). 

Analyses show that approximately 144 high schools out of the 1,499 total public high 

schools in Texas are needed to participate in the study. ED’s contractor anticipates

being able to recruit about 80 high schools via email. ED’s contractor also anticipates

needing to contact approximately 150 high school principals via telephone in order 

to recruit an additional 64 high schools. To recruit additional high schools, ED’s 

contractor will begin by contacting other high schools within the same districts as 

those that have already agreed to participate. If this does not result in a sufficient 

number of high schools, random numbers will be assigned numbers to each of the 

high schools in Texas that have not responded to the recruitment emails, and the 

schools will be sorted in chronological order by these random numbers. Starting 

with the smallest number, high schools will be contacted via telephone and asked to 

participate in the study.

2. School mailing verification. The intervention for this study consists of dissemination 

of informational materials to the parents of sophomores who entered grade 9 in a 

Texas public high school during the 2014-15 school year. Informational materials will 

be sent to parents via the U.S. mail. Participating schools will be supplied with 

enough postage paid envelopes containing study materials for these parents. Along 
with these materials, schools will be provided with one postage-paid envelope 

addressed to ED’s contractor. The envelope will contain the name of the school from 

which it was sent, and schools will be asked to mail this envelope at the same time 

as the informational materials. ED’s contractor will use these envelopes to 

determine which high schools have mailed the informational materials and when 

they were sent. If schools have not mailed the informational materials within one 

week of the mailing deadline, ED’s contractor will conduct reminder telephone calls

to high school principals. OMB approval is being sought for mailing of the envelopes 

to ED’s contractor, as the receipt (or non-receipt) of these letters provides data 

which will be used to assess implementation fidelity. 

3. Extant school and student data files from the Texas Education Agency. For this 

project, REL Southwest will use de-identified versions of TEA’s Public Education 

Information Management System (PEIMS), statewide assessment files and Texas 

Academic Performance Report (TAPR) files data (see attachment A-4)

5

. Since ED’s 

contractor is requesting data for all students in participating schools in the state as 

opposed to requesting a customized report, it is not anticipated that this data 

collection activity will place much of a time burden on TEA staff—not more than 32

hours (16 hours each of two times). TEA regularly prepares files in this manner for 

inclusion in the state longitudinal database housed in the Education Resource 

Centers located in Austin and Dallas, Texas. 

3. Use of Automated, Electronic, Mechanical, or Other Technological Collection 

Techniques

The data collection plan reflects sensitivity to issues of efficiency, accuracy, and respondent 

burden. To address the study’s research questions, the contractor will collect data using 

electronic data collection tools. The electronic tools include the following: 

 A secure electronic file transfer protocol site that allows TEA to transfer extant student 

and school records to ED’s contractor in an efficient and secure way. 

 Email messages to district superintendents and high school principals containing 

information about the study and inviting them to participate. 

 

5

TEA will provide ED’s contractor with data files in which student identification numbers have been encrypted. The 

encryption process will be the same for both files, which will allow us to link the files. 
 Email reminders to the principals of high schools that have not disseminated study 

materials by the mailing deadline. 

4. Efforts to Avoid Duplication of Effort

To the extent possible, this project will rely on extant administrative data or existing documents 

that are available for students and schools in Texas, rather than asking individuals to provide 

the data for this study. The only data to be collected that will be unique to this study will be 

obtained through the school recruitment activities that we will conduct. All other data used in 

this study will come from extant data sources.

We are unaware of any other efforts to provide parents with information about the new high 

school graduation mathematics requirements and how the extent to which they are aligned 

with the admissions requirements for most public colleges and universities in the state. 

Through a separate project, we have determined that many Texas public school districts and 

high schools have disseminated materials regarding the new high school graduation 

requirements, but we are unaware of any that focus explicitly on mathematics.

5. Sensitivity to Burden on Small Entities

The use of state-level administrative records will reduce the burden on districts by ensuring 

that only the minimum amount of original data is requested from districts in order to meet the 

objectives of this study. Aside from recruitment activities, ED’s contractors will not contact 

districts to request additional data.

All principals agreeing to allow their schools to participate in the study will be asked to sign an 

agreement to participate form (Attachment A-12). Schools participating in the study will be 

asked to print and place address labels on the envelopes containing the intervention materials. 

However, there is no data collection, and therefore no data collection burden, associated with 

the intervention itself beyond sending one envelope to ED’s contractor. By agreeing to 

participate in the study, principals agree to disseminate the materials. Schools will be 

reimbursed for the cost of student address labels, printing, and staff time. The envelopes will be 

postage paid. 

Schools will be asked to mail an envelope addressed to ED’s contractor at the same time as the 

intervention materials. These envelopes will be pre-addressed and postage paid. As such, they 

place very minimal burden on participating schools. 
 

6. Consequences to Federal Program or Policy Activities if the Collection Is Not 

Conducted or Is Conducted Less Frequently Than Proposed

The Education Science Reform Act of 2002 states that the central mission and primary function 

of the regional education laboratories is to support applied research and provide technical 

assistance to state and local education agencies within their region (ESRA, Part D, section 

174[f]) (see attachment A-8). If the proposed data were not collected, REL Southwest would 

not be fulfilling its central mission to serve the states in the region and provide support for 

evidence-based research. The research questions addressed in this study respond to questions

raised by TEA, which is a constituent member of the REL Southwest. If the proposed data were 

not collected, TEA would not know if providing students with information about the importance 

of completing algebra II for college access and success has an impact on the percentage of 

students who enroll in and complete algebra II by the end of their junior year. Because Texas is 

a leader among states as it relates to high school graduation standards (they were one of the 

first states to adopt a requirement that students complete Algebra II to graduate), the results of 

this study may also inform decisions regarding high school graduation requirements 

nationwide. 

7. Special Circumstances

This request for OMB clearance does not include any of the stipulated special circumstances 

and thereby fully complies with regulations.

8. Federal Register Announcement and Consultation

Federal Register Announcement

A 60-day Federal Register Notice was published on April 17, 2015. There have not been 

any comments posted during the 60-day comment period. A 30-day notice was 

published on [DATE TO BE COMPLETED BY IES].

Consultations Outside the Agency

ED and/or the REL Southwest contractor have consulted with individuals regarding the 

availability of data, the soundness of the evaluation design for addressing evaluation 

questions, and the clarity of measures. Specifically, a technical working group (TWG) 

comprising experts in research methodology and REL Southwest’s core areas of 

emphasis, which was assembled by the REL Southwest contractor to review studies. The 
TWG met twice, April 29, 2014 and August 4, 2014, to discuss the changes to the 

graduation requirements being implemented as a result of HB 5, the study 

methodology, and measures. The contractor was required to submit to ED the TWG 

comments and the contractors’ plan for addressing those comments (see appendix A11).

Members of the TWG include:

Dan Goldhaber, Ph.D.

Director, CALDER (National Center for Analysis of Longitudinal Data in Education 

Research)

Vice President, American Institutes for Research (AIR) 

Director, Center for Education Data & Research (CEDR), University of Washington 

Bothell

Co-Editor, Education Finance and Policy

3876 Bridge Way N, Suite 201

Seattle, WA 98103

Ph: 206-547-1562

Fax: 206-547-1641

E-mail: dgoldhab@uw.edu

Geoffrey Borman, Ph.D.

Professor of Education, University of Wisconsin—Madison

Deputy Director of the University of Wisconsin's Predoctoral Interdisciplinary Research 

Training Program

Senior Researcher, Consortium for Policy Research in Education.

348 Education Building

1000 Bascom Mall

Madison, WI 53706-1326

Ph: 608-263-3688

Fax: 608-265-3135

E-mail: gborman@education.wisc.edu

Johannes M. (Hans) Bos, Ph.D.

Vice President and Program Director, International Development, Evaluation, and 

Research (IDER) Program

American Institutes for Research

2800 Campus Drive, Suite 200

San Mateo, CA 94403

Ph: 650-843-8100
Fax: 650-843-8200

E-mail: jbos@air.org

W. Steven Barnett, Ph.D.

Board of Governors Professor and Director of the National Institute for Early Education 

Research

Rutgers University

73 Easton Avenue

New Brunswick, NJ 08901

Ph: 848-932-4350 x23132

Fax: 732-932-4360

E-mail: sbarnett@nieer.org

Unresolved Issues

There are no unresolved issues.

9. Payment or Gift to Respondents

This request for OMB clearance does not include any monetary incentives to respondents. 

Schools participating in the study will be asked to print and place address labels on the 

envelopes containing the intervention materials. However, there is no data collection, and 

therefore no data collection burden, associated with the intervention itself beyond sending one 

envelope back to ED’s contractor. By agreeing to participate in the study, principals agree to 

disseminate the materials. Schools will be reimbursed for the cost of student address labels, 

printing, and staff time—up to $150. The envelopes will be postage paid. Schools will be 

provided with free study materials and will be offered copies of the final report.

10. Data Confidentiality

The data collection efforts that are the focus of this clearance package will be conducted in 

accordance with all relevant federal regulations and requirements. The Southwest REL will be 

following the new policies and procedures required by the Education Sciences Reform Act of 

2002, Title I, Part E, Section 183 requires “All collection, maintenance, use, and wide 

dissemination of data by the Institute” to “conform with the requirements of section 552 of 

title 5, United States Code, the confidentiality standards of subsection (c) of this section, and 

sections 444 and 445 of the General Education Provision Act (20 U.S.C. 1232g, 1232h).” These 

citations refer to the Privacy Act, the Family Educational Rights and Privacy Act, and the 
Protection of Pupil Rights Amendment.

The project has been approved by E&I Review Services, which serves as SEDL’s Institutional 

Review Board to review research involving human subjects. E&I is registered with the Office of 

Human Research Protection (OHRP). E&I’s IRB Organization number is 000065. E&I’s IRB 

Registration number, effective until November 28, 2015, is IRB00007807 (see attachment A-7).

For student information, the data collection efforts will ensure that all individually identifiable 

information about students, their academic achievements, their families and information with 

respect to individual schools, shall remain confidential in accordance with section 552a of Title 

5, United States Code, the confidentiality standards of subsection (c) of this section, and 

sections 444 and 445 of the General Education Provision Act. The study will also adhere to 

requirements of subsection (d) of section 183 prohibiting disclosure of individually identifiable 

information as well as making the publishing or inappropriate communication of individually 

identifiable information by employees or staff a felony. All administrative records will be sent to 

ED’s contractor by TEA using a file transfer protocol (FTP). Access to the FTP site will be 

password protected, and all data will be immediately deleted from the FTP site upon successful 

download by ED’s contractor. All data files will be stored on secure server administered by ED’s 

contractor. Extant student data records will already have been de-identified by TEA prior to 

transfer. That is, all student identification numbers and school identification numbers will have 

been systematically replaced by TEA using algorithm designed by TEA. 

ED’s contractor will protect the confidentiality of all information collected for the study and will 

use it for research purposes only. No information that identifies any study participant will be 

released publicly. Information from participating institutions and respondents will be presented 

at aggregate levels in reports. Information on respondents will be linked to their institution but 

not to any individually identifiable information. No individually identifiable information will be 

maintained by the study team upon study completion.

To protect confidential data, only the contractor’s data management staff, investigators, and 

research staff will have access to the data files on a “need-to-know” basis. Any identifiable 

variables, raw data, or derived variables will be stored in encrypted files on a secure data 

management site. Access to this site will be limited to staff assigned to the project. Any data 

obtained for this study will be used only for statistical and descriptive analyses. All identifiers 

will be destroyed as soon as they are no longer required. Study reports will not identify the 

name of any specific analysis unit (e.g., students, school staff members, or schools). In no case 

will information be reported when the total number for a quantity represents fewer than four 

cases. Moreover, any data that permit identity disclosure, when used in combination with other 

known data, will not be published or made available in restricted-use files. 
All members of the study team have obtained their certification on the protection of human 

subjects in research, and REL Southwest staff members will also have obtained federal security 

clearances. The REL study team will submit to the NCEE security officer a list of the names of all

people who will have access to respondents and data. All staff members working on the project 

who have access to the data or to respondents will be required to sign a confidentiality pledge 

and affidavits of non-disclosure (see copies of the forms in Attachment A-10; we will obtain the 

appropriate signatures). The project team will track new staff and staff who have left the study 

and ensure that additional signatures will be obtained or clearances will be revoked. 

11. Additional Justification for Sensitive Questions

No questions of a highly sensitive nature appear in any study materials, including the 

recruitment materials. 

12. Estimates of Hour Burden

There are three components for which ED’s contractor has calculated hours of burden for this 

clearance package: (1) school recruitment activities, (2) school mailing verification, and (3) 

extant student records data collection. Table 3 shows the hourly burden overall and for each

component. The total burden associated with this study is 399 hours. For each of the three 

years of the study, the annualized burden is estimated to be 133 hours. This burden estimate 

includes the time required to recruit schools to participate in the study—350.6 hours—the time 

to verify mailing of study materials—16 hours—and the burden estimate for extant data 

collection—32 hours. For this data collection, the burden was estimated based on the 

contractor’s performance of recruitment activities, as well as the contractor’s previous 

experience obtaining extant data from TEA. The annualized number of responses is 1,468 (a 

total of 4,404across three years).
Table 3. Time Burden Estimates for the REL Southwest Study of HB 5

Instrument

Person 

Incurring 

Burden

Number of 

Respondents

Responses 

per 

Respondent

Hours per 

Response

Total 

Burden 

(Hours)

1. Recruitment emails to 

principals

High school 

principal 1499 1 0.08 119.9

2. First follow-up 

recruitment email to 

principals

High school 

principal 1350 1 0.08 108

3. Second follow-up 

recruitment email to 

principals

High school 

principal 1215 1 0.08 97.2

4. Recruitment telephone 

calls with principals

High school 

principal 150 1 .17 25.5

5. School mailing 

verification

School 

administrative 

staff

144 1 .08 11.5

6. School mailing 

verification follow-up phone 

calls

School 

administrative 

staff

45 1 .08 3.6

7. Extant student records 

data

State data 

manager

1 2 16 32

Total -- 4404 -- -- 399

We assume an average of 5 minutes per respondent for the initial and follow-up emails (a total of 15

minutes for email recruitment) and an additional 10 minutes for telephone call recruitment. We need 

approximately 144 high schools out of the 1499 total public high schools in Texas to participate in the 

study. We anticipate that we will be able to recruit about 80 high schools via email. We also anticipate 

needing to contact approximately 150 high school principals via telephone in order to recruit an 

additional 64 high schools. To recruit additional high schools, we will begin by contacting other high 

schools within the same districts as those that have already agreed to participate. If this does not 

result in a sufficient number of high schools, random numbers will be assigned numbers to each of 

the high schools in Texas that have not responded to the recruitment emails, and the schools will be 

sorted in chronological order by these random numbers. Starting with the smallest number, high 

schools will be contacted via telephone and asked to participate in the study.
Burden for Recruitment Activities

The total estimated burden for recruiting schools to participate in the study is 350.6 hours, 

including 325.1 hours for email message to high school principals, and 25.5 hours for telephone 

calls with high school principals. Recruitment activities will take place during year 1 of the 

study.

Burden for School Mailing Verification

The total estimated burden for verifying that high schools have disseminated study materials is 

16 hours. It should take minimal time for schools to mail the pre-addressed, postage-paid 

envelopes, and follow-up phone calls with school administrative staff assigned to mail study 

materials are assumed to take no more than 5 minutes. It assumed that follow-up telephone 

calls will need to be conducted with administrative staff from approximately one-third of the 

participating schools. 

Burden for Extant Data Collection

The total estimated burden for TEA to compile and transmit secondary data to ED’s contractors 

is 32 hours. This calculation assumes one data manager works a collective total of 32 hours (4 

total days) on compiling the data request. ED’s contractor is requesting complete data sets (all 

variables) from the data files maintained by TEA, rather than requesting a customized dataset, 

which would be more time consuming. The complete files will contain extraneous variables, 

such as data flags, variables that provide duplicate data, and variables used to create other 

variables. These extraneous variables will be deleted by ED’s contractor prior to analysis of the 

data files. As such, the burden to downloading the data files and transmitting them to ED’s 

contractor is very low. 

The total cost to respondents for the components of this study that require burden from

outside sources—the recruitment activities, school mailing verification, and the extant student 

records data collection—is provided in Table 4. The total respondent cost associated with this 

study is approximately $15,526. The annualized cost for this three-year study is $5,175.33. The 

cost of the recruitment activities is $14,024 ($13,004 for the high school principal emails; 

$1,020 for the high school principal telephone calls); the cost of school mailing verification is 

$254 ($207 for mailing the envelopes; $47 for follow-up phone calls) the cost of the extant data 

collection is $1,280. There are no start-up costs associated with this data collection.

Table 4. Estimates of Annualized Costs for Respondents

Tasks Type of Respondent

Total 

Burden 

Hours

Hourly 

Wage 

Rate1

Monetary 

Cost of 

Burden
1. Recruitment emails to principals High school principal 119.9 $40 $4,796

2. First follow-up recruitment email 

to principals High school principal 108 $40 $4,320

3. Second follow-up recruitment 

email to principals High school principal 97.2 $40 $3,888

4. Recruitment telephone calls with 

principals

High school principal

25.5 $40 $1,020

5. School mailing verification School 

administrative staff 11.5 $18 $207

6. School mailing verification 

follow-up phone calls

School 

administrative staff 3.6 $18 $47

5. Extant student records data State data manager 32 $39 $1,248

Total -- 396.7 -- $15,526

NOTE: The hourly wage rates for district administrative staff are based on mean wage rates in Texas reported by the 

Bureau of Labor Statistics (2013). For district superintendents and high school principals the mean wage for education 

administrators of elementary and secondary schools is used ($39.59). For school administrative staff the mean wage 

for office and administrative support workers is used ($17.90). For state data managers the mean wage for 

statisticians is used ($38.80). 

13. Estimate of Total Annual Cost Burden to Respondents or Record-Keepers

There are no start-up costs to respondents.

14. Estimates of Annualized Cost to the Federal Government

The annualized cost to the federal government for all project activities is $162,933.33. The 

estimated total cost for the three-year project is $488,800.

15. Reasons for Program Changes or Adjustments

This is a new study.
16. Plan for Tabulation and Publication and Schedule for Project

Tabulation plans

All results for REL studies are made available to the public through peer-reviewed reports that 

are published by IES. The extant student records data will not be turned over to the REL’s IES 

project officer. 

Publication plans

To answer the confirmatory research questions, ED’s contractor will utilize multilevel models to

compare algebra II enrollment and completion rates by the end of junior year for students in 

schools that received information about the role of algebra II in college access and success and 

students in schools that did not receive this information. To answer the exploratory research 

questions, ED’s contractor will include interaction terms into the model used to analyze our 

confirmatory research question in order to look for differential impacts of providing 

information about the role of algebra II for college access and success for schools with high 

minority populations and high low-income populations. ED’s contractor will also assess whether 

there are differential impacts in schools with a higher percentage of low-achieving schools. 

The project schedule is presented in Table 5.

Table 5. Schedule of Activities

Product/Activity Date

Draft study proposal to REL Southwest COR May 2014

Revised draft proposal to RPR September 2014

Draft OMB package to COR December 2014

Grade 9 cohort begins high school August 2014

Final study proposal November 2014

Notice of IRB clearance November 2014

Final OMB approval August 2015

Recruit high schools to participate in study October 2015 - December 2015

Send research/informational brochures January 2016 – End-February 2016

Students begin selecting courses for their junior year End-February 2016 – Early March 2016

Data analysis: Course completion data available for students who took 

algebra I in grade 9 

June 2017

Dissemination of limited distribution memo to TEA Late Summer- Early Fall 2017

Dissemination of public reports Late Fall 2017
17. Approval Not to Display the Expiration Date for OMB Approval

Approval not to display the expiration date for OMB approval is not requested.

18. Exception to the Certification Statement

No exceptions to the certification statement are being sought.
References

Bureau of Labor Statistics (2013). May 2012 state occupational employment and wage 

estimates: Minnesota. Washington, DC: Author. Retrieved 

http://www.bls.gov/oes/current/oes_mn.htm#00-0000.

U.S. Department of Education. (2010). A blueprint for reform: The reauthorization of the 

Elementary and Secondary Education Act. Washington, DC: Author. Retrieved from 

http://www2.ed.gov/policy/elsec/leg/blueprint/blueprint.pdf\

Attachment A-1. Information Materials (Intervention)

See attachment
Attachment A-2. School Principal Email

See attachment
Attachment A-3. School Principal Follow-up Email

See attachment
Attachment A-4. School Principal Telephone Call Script

See attachment
Attachment A-5. School Mailing Verification Telephone Script 
Attachment A-6. Student Records Data

See attachment
Attachment A-7. IRB Approval

See attachment
Attachment A-8. Educational Sciences Reform Act (ESRA)

See attachment
Attachment A-9. Federal Register Notices

See attachment
Attachment A-10. Confidentiality Form and Affidavits

See attachment
Attachment A-11. Technical Working Group Suggestions

See attachment
Attachment A-12. School Agreement to Participate Form

See attachment