ED Responses to OMB Comments

Memorandum United States Department of Education

Institute of Education Sciences

National Center for Education Statistics

TO: Rochelle W. Martinez October 3, 2008

OMB Desk Officer

FROM: Tracy Hunt-White and James Griffith

Postsecondary Studies Division, NCES

SUBJECT: Responses to OMB for BPS:04/09 Transcript Collection

1. At the Census Bureau, they don't mention the name of a particular survey.  They say something generic like "a Census Study." Is there a need to be explicit about whether the transcripts we are seeking are for B&B and/or BPS?  Why is it important to give the study name instead of just using NPSAS or "an NCES study"? Is there some IRB or legal reason that we need to do this?

There is no IRB requirement that the specific studies be identified. Since the original submission, it was decided that a single name for the transcript collection would help to reduce the confusion that could potentially result from institutions trying to determine whether a transcript is being sent for a B&B sample member or a BPS sample member. There is an advantage to having a name for institutions to reference should they need to contact NCES or RTI International, and particularly when doing so without the names and telephone numbers provided for study staff. The combined B&B/BPS transcript collection has been titled the 2009 Postsecondary Education Transcript Study (PETS:09), continuing the name that was used for the last postsecondary transcript collection conducted for the NELS:88 sample. A single PETS:09 website will be used to organize the transcript collection for both longitudinal studies.

2. Do we need to provide SSNs to the schools in order to get the correct transcripts?  We've gotten SSNs from the NPSAS schools, but for BPS we may be potentially providing SSNs to schools that have not provided us with SSNs before for the student. There is concern about providing SSNs to an entity that did not have them before.

RTI will not be providing Social Security Numbers (SSNs) to any institutions when transcripts are requested, even when those transcripts are requested from the NPSAS institution that provided the SSN originally. RTI will load the student’s name, date of birth and, when available, Student ID. Institution contactors who will staff the PETS:09 Help Desk will have access to student SSNs should institutions need more information that will allow them to differentiate sample members with similar names. However, they will be instructed to first use other available information, such as enrollment dates and field of study, to identify the student before resorting to SSN. In order to confirm SSN, Help Desk staff will verify the last four digits of the number, rather than volunteering all or part of the SSN.