SMART Campus Information Sharing Response Project Justification

Campus Information Sharing and Response Project

USDOJ SMART Office Fellowship

Supporting Statement for Paperwork Reduction Act

A. JUSTIFICATION

1. Necessity of Information: Currently institutions have varied means of information sharing between campus and community partners (including law enforcement) and with other institutions of higher education. In the past few years, two states passed laws requiring institutions to issue notations on the academic transcripts of students found responsible for violating the campus sexual misconduct policy. Other schools have adopted policies on this issue, regardless of legal mandates. Recently, the American Association of Collegiate Registrars and Admissions Officers (AACRAO) released guidance that colleges and universities should “provide some form of notice to receiving institutions when serious behavioral misconduct occurs.” The Association of Student Conduct Administration (ASCA) has also suggested guidance to its members on this issue that “recommends that all institutions place an appropriate notation on an academic transcript to indicate when a student is ineligible to re-enroll at that institution as a consequence of disciplinary action.” The Campus Information Sharing and Response project aims to identify college and university responses to sanctioned students, as well as registered sex offenders employed or enrolled on a campus.

This is a one-time collection project.

2. Purpose for Use: Many campuses do not have a comprehensive policy addressing information sharing of and responses to individuals found responsible and sanctioned for sexual misconduct returning or transferring to campus, nor sex offenders working or taking classes on campus. The survey will provide an overview of institutions of higher education responses. The SMART Office has expertise in this area, and with direct input from colleges and universities, the SMART Office could provide sample policies or guidance on these topics.

3. Use of Information Technology: The surveys will be completed on the platform; Survey Monkey and all responses are anonymous. SurveyMonkey is an online survey development cloud-based software. 

4. Identification of Duplication: The information collected is specific to the SMART Office. There is no other questionnaire of this information in the public domain.

5. Impact on Small Businesses or Other Entities: This information is to be collected only from colleges and universities where even the smallest schools deliver services to at least hundreds of students.

There is no direct or indirect impact on small businesses or other entities, as they are not are eligible to participate.

6. Consequences if Collection is not Conducted: If information is not collected, there will not be any information about what campuses are currently doing in these cases. As a growing number of states are requiring some form of transcript notation, federal agencies will be asked to provide guidance on this question without the benefit of understanding current practices.

7. Special Circumstances: There are no special circumstances that would require any campus to provide information.

8. Federal Register Publication and Consultation: The 60-day and 30-day Federal Register notices were published to inform and solicit comments from the public. There were approximately two comments received.

9. Payment to Respondents: There are no payments or gifts provided to the respondents.

10. Assurance of Confidentiality: Pursuant to Title 28 of the Code of Federal Regulations, Part 22, project staff have an obligation to those we interview or those who respond to questionnaires to protect their identities and the information they provide to the Campus Information Sharing and Response Project. The identity of persons interviewed or responding to the questionnaire and the related data are to remain confidential. Removal of names or disclosure of identities and related information is strictly forbidden. Contents of interviews or questionnaire responses are not to be discussed with anyone except project staff, and only as it is necessary to complete the assigned work. Additionally, sensitive interview or questionnaire response information should not be discussed anywhere it could be overheard by persons who are not authorized to know this information. Project staff have signed statements respecting this confidentiality.

11. Questions of a Sensitive Nature: Although the topic is about sexual misconduct, the questions are about protocol, policies and practices and therefore would not be considered of a sensitive nature.

12. Estimates of the Hour Burden: On average it is estimated that there will be 800 respondents responding to the questionnaire. The questionnaire takes approximately 60 minutes to complete. No preparation time is required to complete the questionnaire.

800 respondents x 60 minutes = 48,000 minutes/60 minutes per hour=800 hrs.

13. Estimate of the Total Annual Cost Burden: There is no cost burden to the respondents.

14. Estimates of Annualized Cost to the Federal Government: Given that this questionnaire will be reviewed, analyzed and summarized by the SMART Office fellow, there is no additional cost to the federal government.

15. Program Changes or Adjustments: This is a new questionnaire and will not directly impact any program.

16. Publishing Information: There are no plans to publish an external report of this information.

17. Approval for not Displaying OMB Approval:

18. Certification Statement for Paperwork Reduction Act Submission: See attached Certification Statement.

B. STATISTICAL METHODS

Statistical methods will not be used in this information collection.