1840-0841 Supporting Statement Part A 8.1.24

OMB Number: 1840-0841 Revised: 8/1/24

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

     

A. Justification

1. Explain the circumstances that make the collection of information necessary. What is the purpose for this information collection? Identify any legal or administrative requirements that necessitate the collection. Include a citation that authorizes the collection of information. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change). If revised, briefly specify the changes. If a rulemaking is involved, list the sections with a brief description of the information collection requirement, and/or changes to sections, if applicable.

The Higher Education Opportunity Act (HEOA) of 2008 (20 USC 1140p-1140r) called for the creation of a national technical assistance center to provide information to students, families, and professionals to improve access to higher education for students with disabilities.

In accordance with section 777(a)(4)(c) of the HEOA, the National Center for College Students with Disabilities (NCCSD) is responsible for building, maintaining, and updating a database of disability support services information with respect to institutions of higher education (IHEs), or for expanding and updating an existing database of disabilities support services information with respect to IHEs. Such a database has been available to the general public through a website built to high technical standards of accessibility practicable for the broad spectrum of individuals with disabilities – the CEDAR Database at www.CEDARdatabase.org. (For applicable HEOA section, see https://www.gpo.gov/fdsys/pkg/PLAW-110publ315/html/PLAW-110publ315.htm.)

The information collection that supports this database is currently approved under OMB number 1840-0841. The NCCSD plans to do a national update of the CEDAR database, with expansion of the database to include all non-degree-granting IHEs in the U.S. The U.S. Department of Education (Department) is requesting a revision of the survey for the following reasons: to add non-degree-granting IHEs to the respondent universe; to change the timeframe for and revise one question (Question 8); to revise the possible responses to one question (Question 22); and to add three new questions regarding faculty/instructor disability training (Questions 23-25). The revised survey is attached. The revised and additional questions are:

• Previously, Question 8 asked for information from the past five years, and Questions 7 and 9 asked for information from the previous three years. Questions 7, 8, and 9 now all ask for information from the past three years.

• Question 8 previously read “Within the last five years, how common has it been for your institution and/or disability services provider to serve these specific populations of students with low incidence disabilities?” now changed to “Within the last three years, how common has it been for your institution and/or disability services provider to serve these specific populations of students, students in specific academic fields or interests, or students with a shared background?”

Possible responses to the question remain unchanged except for one addition under the Category of “Students with disabilities in specific academic fields or interests,” which now includes “Students in technical fields, pursuing careers that require a license, certification, special diploma, or other non-degree qualifications.” “Students in prison or other parts of the criminal justice system” was changed to “Incarcerated students or students in the criminal justice system.”

• Responses to Question 22 have been updated to include the following options:

• Yes, for all faculty

• Yes, for adjunct (part-time) instructors

• Yes, for graduate students who are teaching or assisting faculty in courses

• Yes, for new faculty

• Yes, but only in specific departments or colleges

• No, only optional disability training is offered to one or more types of faculty and instructors

• No (skip questions 23-25)
  
  

• Questions 23, 24, and 25, listed below, have been added:

23. Additional question: How is the faculty/instructor disability training offered?

• In-person

• Online synchronous (all participants must be online at the same time)

• Online asynchronous (participants may complete training at times that work for them)

• Hybrid: part is in-person and part is online

• Training is offered in print (e.g., a faculty handbook or manual)

24. Additional question: Which of the following topics are included in the faculty/instructor disability training? (check all that apply):

• Information about accommodations (e.g., determining accommodations, implementing accommodations)

• Information about the ADA and Section 504

• Universal design for teaching and learning

• Information about types of disabilities

• How to create accessible documents

• How to hold accessible events

• Research-based strategies for faculty to increase retention and degree completion rates for students with disabilities

• What to do if faculty are concerned about student behaviors

• How to make technology (e.g., PowerPoints, online courses, films) accessible

• Information about ableism

• Information about intersectionality or diversity among people with disabilities

• Information for faculty/instructors with disabilities

• Other [open response box]
  
  

25. Additional question: If your campus offers certification, digital badges, or other recognition for faculty/instructors who complete the disability training, do you also require faculty maintain or renew that certification at any point?

• Yes

• No

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

In 2015, the U.S. Department of Education, Office of Postsecondary Education (OPE) awarded one grant award under the National Center for Information and Technical Support for Postsecondary Students with Disabilities Program to build a database of disability support services information at IHEs. This Center is named the National Center for College Students with Disabilities (NCCSD); it was originally located at the Association on Higher Education and Disability (AHEAD). It was re-awarded in 2021 and is now housed at the University of Minnesota’s Institute on Community Integration.

The NCCSD established a uniform dataset across all degree-granting IHEs in the United States, called the CEDAR Database (www.CEDARdatabase.org). The dataset includes:

1. Campus contact information for disability services;

2. Support services available, including academic and nonacademic supports such as classroom accommodations, accessible instructional materials, and financial aid;

3. Accommodations policies;

4. Campus accessibility; and

5. Campus advisory structures, training, and educational programming to enhance awareness of disability across campus.

The resulting data is available free and online to the general public, including students with disabilities, their families, and professionals, as well as other interested parties such as researchers and policy makers. The NCCSD has also received informal feedback from graduate students about usefulness of the CEDAR Database in searching for graduate schools, even though the database was set up for undergraduates. In addition, the database has been used by the NCCSD for technical assistance, such as helping students find their disability services office or a campus with a disability studies program.

The NCCSD and the Department of Education have also discussed possible future linkages between the CEDAR Database and other resources available to prospective students in the College Affordability and Transparency Center (https://collegecost.ed.gov/) or College Navigator (https://nces.ed.gov/collegenavigator/), which includes a link to Federal Student Aid. Currently, CEDAR Database information about IHEs’ percentages of students with disabilities is more accurate than College Navigator. There are no resources for students with disabilities in the College Affordability and Transparency Center or the Federal Student Aid website (https://studentaid.gov/h/apply-for-aid/fafsa), with the exception of information about how to discharge federal loans if students become totally disabled and unable to work. Discussions about possible collaborations are ongoing.

As of January 1, 2024, the Department of Education has established a new research center on colleges students with disabilities at the University of Texas - Austin called the National Disability Center for Student Success (https://nationaldisabilitycenter.org/). It is highly likely that the research center will utilize CEDAR Database information in their work, including identification of all IHEs and disability services providers. They may also want to work with the NCCSD on research using the CEDAR Database data. The NCCSD has already collaborated with other federally-funded national centers working on disability and higher education concerns (e.g., Think College, the National Deaf Center) to reflect any needs they may have or research they have already done. For example, CEDAR Database searches can identify campuses with inclusive higher education programs for students with intellectual disabilities, because the NCCSD utilized existing lists from Think College. There is also a question about whether the IHE has expertise with culturally Deaf students using American Sign Language. This makes the database more useful for other national centers.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Please identify systems or websites used to electronically collect this information. Also describe any consideration given to using technology to reduce burden. If there is an increase or decrease in burden related to using technology (e.g. using an electronic form, system or website from paper), please explain in number 12.

The survey is distributed to IHEs using Qualtrics. All data is collected in a secure online database that was created using software purchased from Intuit QuickBase (quickbase.intuit.com). All data entry, tracking, and retrieval is electronic. A web-based data collection system was determined to be the best approach for several reasons:

1. Given the longitudinal nature of the project, a web-based information system reduces burden by allowing IHEs to review the previous year's information easily.
   
   

2. A web-based system increases accuracy, with IHEs entering data that does not need to be modified or re-entered in any way.
   
   

3. The system provides a secure mechanism for transmittal of data.
   
   

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The CEDAR Database remains the only centralized source of information about disability support services and other disability resources at IHEs, inclusive of all types of IHEs and all types of disabilities. The CEDAR Database is based upon statutory authority to build, maintain, and update the database. Because it is provided to the general public and focuses on disability, it requires high technical standards for accessibility.

College Navigator provides information about the percentage of students with disabilities at IHEs and links to disability service offices, but the CEDAR Database has more accurate and complete data because disability services professionals provide the data. Large federal data sources (e.g., the Integrated Postsecondary Education Data System and College Navigator) do not gather information about campus disability services or accessibility for students with disabilities. There are a few existing databases or lists of information about specific types of disabilities, such as students with intellectual disabilities (https://thinkcollege.net/college-search) or autism (https://collegeautismspectrum.com/collegeprograms/). Other online lists attempt to rank IHEs and do not collect information about all types of IHEs or types of disabilities (e.g., https://www.bestvalueschools.org/colleges-for-students-with-autism/). There are also books with information about programs for specific types of disabilities (e.g., The K&W Guide to Colleges for Students with Learning Differences, which is not published annually).

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less than 50,000.

Collection of information does not involve small businesses or other small entities.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Without this information, students with disabilities and their families may continue to experience barriers in accessing higher education. They would not have a way to get full knowledge of the campus resources and accessibility they are entitled to under the Americans with Disabilities Act. Families, special education personnel, disability services professionals in higher education, and postsecondary admissions officers would also not have information in the database and would not be able to adequately advise students with disabilities in the college search process. The NCCSD, the Department of Education, and other entities including policymakers would lose a valuable source of data and information about the current state of college students with disabilities and their services.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

There are no special circumstances involved with this data collection.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.

Include a citation for the 60 day comment period (e.g. Vol. 84 FR ##### and the date of publication). Summarize public comments received in response to the 60 day notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. If only non-substantive comments are provided, please provide a statement to that effect and that it did not relate or warrant any changes to this information collection request. In your comments, please also indicate the number of public comments received.

For the 30 day notice, indicate that a notice will be published. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instruction and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years – even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The Department published a 60-day Federal Register notice as required by 5 CFR 1320.8(d) on May 28, 2024, to solicit comments on the information collection prior to submission to OMB. Two respondents submitted comments but only one set of comments was relevant to the information collection. The Department has reviewed and responded in writing to these comments.

A separate 30-day Federal Register notice will be published to solicit public comment on the collection. The Department will summarize comments received in response to this notice and describe actions taken by the agency in response to these comments.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.

No payments or gifts are being provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided.¹ If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentiality of the data. If no PII will be collected, state that no assurance of confidentiality is provided to respondents. If the Paperwork Burden Statement is not included physically on a form, you may include it here. Please ensure that your response per respondent matches the estimate provided in number 12.

The survey includes the following privacy notice:

The personally identifiable information requested on this form is collected through authorization under the Higher Education Opportunity Act, which mandates that the U.S. Department of Education build, maintain, and update a publicly available website containing disability support services information from all degree-granting and non-degree-granting institutions of postsecondary education. Your participation will ensure this website is accurate and reflects the most up-to-date information available. The information you provide is voluntary. Information about the person completing this survey will not be disclosed outside of the NCCSD and the Department of Education. Information you provide for all other parts of the form, however, including contacts for the office or person providing disability services at your institution, will be displayed on the publicly available website (the CEDAR Database at www.CEDARdatabase.org). In addition, there may be circumstances where information may be shared with a third party, such as a Freedom of Information Act request, court orders or subpoena, or if a breach or security incident would occur affecting the system.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

No questions of a sensitive nature are included in the data collection.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Provide an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. Address changes in burden due to the use of technology (if applicable). Generally, estimates should not include burden hours for customary and usual business practices.

• Please do not include increases in burden and respondents numerically in this table. Explain these changes in number 15.

• Indicate the number of respondents by affected public type (federal government, individuals or households, private sector – businesses or other for-profit, private sector – not-for-profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burden in the table below.

• Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. Use this site to research the appropriate wage rate. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14. If there is no cost to respondents, indicate by entering 0 in the chart below and/or provide a statement.

Provide a descriptive narrative here in addition to completing the table below with burden hour estimates.

Estimated Annual Burden and Respondent Costs Table

Please ensure the annual total burden, respondents and response match those entered in IC Data Parts 1 and 2, and the response per respondent matches the Paperwork Burden Statement that must be included on all forms.

In 2022 (the most recent data available), the Department of Education reported a total of 5,916 institutions of higher education (https://nces.ed.gov/fastfacts/display.asp?id=1122). Table 1 below explains how this is also calculated for public and private IHEs. There are 1,892 public, 1,754 private non-profit, and 2,270 for-profit IHEs in the U.S. Of the 5,916, 3,931 are degree-granting institutions, and 1,985 are non-degree-granting institutions. The entire population will be surveyed so there are no sample sizes. We are calculating the total number of respondents as 100%, because in 2019, IHEs filled out the survey in whole, in part, or as just disability services contact information – it is impossible to estimate a valid percentage for each group.

The time required for completion of the CEDAR Database survey is still estimated to be 3 hours. On most campuses, this will consist of two hours of information collection and data entry by the director or coordinator of a disability services office, or, on smaller campuses with no office, by the lead person responsible for providing disability services. It also includes one hour of information collection and overall review by a campus supervisor/director/dean. There are three additional questions in the database, but the information will be readily available when respondents answer questions on other parts of the survey – we expect no additional burden for respondents. The total time required across respondents is 17,748 hours.

Cost estimate for data entry per campus includes two hours for a campus disability services director at an average salary of $76,525/year or $37/hour, based on AHEAD 2020 Professional Benchmark Survey (https://www.ahead.org/professional-resources/information-services-portal/benchmark-data). This is in addition to one hour of support or supervision by a campus professional in a management position (e.g., supervisor, dean, department head), with an average salary of $114,658/year or $55/hour, based on salary reports from IPEDS, summarized by The Chronicle of Higher Education on April 28, 2023 (https://www.chronicle.com/article/how-much-has-noninstructional-employee-pay-changed-over-time). This results in an average cost of $129 per campus (up from $79 in 2019) and an annual cost of $763,164 across all respondents (5,916 IHEs x $129/respondent).

Table 1 Estimates of data collection’s total burden for IHEs.

Information Activity or IC (with type of respondent)	Sample Size (if applicable)	Respondent Response Rate (if applicable)	Number of Respondents	Number of Responses	Average Burden Hours per Response	Total Annual Burden Hours	Estimated Respondents Average Hourly Wage	Total Annual Costs (hourly wage x total burden hours)
Public IHEs	N/A	N/A	1,892	1,892	3	5,676	Disability services director = $37/hour Management = $55/hour	$244,068
Private non-profit IHEs	N/A	N/A	1,754	1,754	3	5,262		$226,266
Private for-profit IHEs	N/A	N/A	2,270	2,270	3	6,810		$292,830
Annualized Totals	N/A	N/A	5,916	5,916	3	17,748		$763,164

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost :      

Total Annual Costs (O&M) : ____________________

Total Annualized Costs Requested :

There will be no capital or start-up expenses required for data collection. Each of the 5,916 IHEs will be able to use existing computers to enter the requested information, so there will be no additional burden beyond the personnel time described above.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

The estimated cost to the Federal government for this data collection over the next year is $65,494, distributed as outlined in Table 2. Fringe benefits are included for salaried staff. Please note that the Lead PI’s total FTE on the grant is .10, the Co-PI’s total FTE is 1.0, and the Associate Director’s FTE is .20. Estimated annual costs for the Federal government are .02 FTE for the Lead PI (at $3,096); .20 FTE for the Co-PI ($31,326); .and .05 FTE for the Associate Director ($6,072), as well as $5,000 for a graduate research assistant (no fringe benefits). Contractual services are with the University of Massachusetts-Boston’s Institute for Community Inclusion (ICI), which developed the database and online version of the survey. UMass-Boston’s ICI will be making edits and updates to the CEDAR Database website, the survey instrument, and collection methods. They will also ensure IHE responses are accurately uploaded to the Database.

Table 2: Estimated cost of data collection for the Federal government.

Annual costs
.02 Lead PI	$3,096
.20 Co-PI and Director of the National Center	$31,326
.05 Associate Director of Outreach and Education	$6,072
Graduate research assistant	$5,000
Contractual Services (UMass-Boston)	$20,000
Total annual cost	$65,494

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in burden result from re-estimating burden and/or from economic phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours, responses and costs (if applicable).

Provide a descriptive narrative for the reasons of any change in addition to completing the table with the burden hour change(s) here.

Table 3 below provides information about changes in the CEDAR database data collection burdens. The addition of non-degree-granting IHEs, which is a program change due to agency discretion, results in an increase of 5,955 burden hours and an increase of 1,985 respondents. The update to the number of degree-granting IHEs currently in operation, which is a change due to adjustment in agency estimate, results in a decrease of 1,956 burden hours and a decrease of 652 responses.

Table 3. Overview of changes in burden hours

	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate
Total Burden		5,955	-1,956
Total Responses		1,985	-652
Total Costs (if applicable)

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Not applicable to this collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not seeking approval to not display the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

There are no exceptions requested.

Because this is a survey, please see Supporting Statement Part B attached.

Work cited:

National Center for Education Statistics. (2022). Educational institutions. FAST FACTS. https://nces.ed.gov/fastfacts/display.asp?id=1122

1 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)

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