Amendment_0001__ED-IES-15-R-0027_Post_High_School_Outcomes_Study.pdf

NSN 7540-01-152-8070 STANDARD FORM 30. (Rev. 10-83) Previous Edition unusable Prescribed by GSA FAR (48 CFR) 53.243

Page of Pages AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1. Contract ID Code

2. AMENDMENT MODIFICATION NO. 3. EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO. 5. PROJECT NO. (if applicable)

6. ISSUED BY CODE 7. ADMINISTERED BY (If other than item 6) CODE

(x) 9A. AMENDMENT OF SOLICITATION NO.

9B. DATED (SEE ITEM 11)

10A. MODIFICATION OF CONTRACT/ORDER NO.

8. NAME AND ADDRESS OF CONTRACTOR (NO., Street, Country, State and ZIP Code)

CODE FACILITY CODE

10B. DATED (SEE ITEM 13)

11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

The above numbered solicitation is amended as set forth in item 14. The hour and date specified for receipt of offers is extended, is not extended.

Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one of the following methods:

(a) By completing items 8 and 15, and returning ______ copies of amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted;

or (c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OR OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. If by virtue of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each telegram or letter makes reference to the solicitation and this amendment, and is received prior to the opening hour and date specified.

12. ACCOUNTING AND APPROPRIATION DATA (If required)

13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.

Check One

A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE

CONTRACT ORDER NO. IN ITEM 10A.

B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying office, appropriation date, etc) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).

C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

D. OTHER (Specify type of modification and authority)

E. IMPORTANT: Contractor is not, is required to sign this document and return _______ copies to the issuing office.

14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible)

Except as provided herein, all terms and conditions of the document referenced in item 9A or 10A, as heretofore changed, remains unchanged and in full force and effect.

15A. NAME AND TITLE OF SIGNER (Type or print)

16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)

15B. CONTRACTOR/OFFEROR 16B. UNITED STATES OF AMERICA

(Signature of person authorized to sign)

15C. DATE SIGNED

(Signature of Contracting Officer)

16C. DATE SIGNED

Attachment Page

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Responses to Clarification Questions Submitted by Interested Parties Request for Proposals #ED-IES-15-R-0027

Post High School Outcomes for Youth with Disabilities

QUESTIONS DEPARTMENT OF EDUCATION RESPONSE

1 Can the agency provide documentation of the age distribution of the respondents to the

NLTS2012?

The age distribution of the NLTS2012 respondents at the time of sampling is as follows:

• For the parent survey (total sample of 12,988), 46.5% are younger than 15 years old, 53.6% between 15-18 years old, and 0.01% older than 18 years old.

• For the youth survey (total sample of 11,128), 45.7% are younger than 15 years old, 53.4% between 15-18 years old and 0.06% older than 18 years old.

2 What proportion of the NLTS2012 sample of 21,959 youth ended up as survey non-respondents and will the non-respondents continue into this new phase of the research program?

Among the respondents, only those who did not give explicit consent to accessing other administrative records will be excluded from Phase II. As noted in Table 2 (page 6) of the PWS, parents of 12,988 sampled youth completed the parent survey and 11,128 youth completed the youth survey. The sample we plan to proceed with is 19,651 youth for school records collection, 19,065 youth for collection of postsecondary and financial aid information, and 3,495 youth for collection of employment and earnings information.

3 Have schools retained study ID’s for participating students, or will the contractor need to re-identify the students prior to requesting transcripts and other school records?

The contractor will be provided the study ID’s along with sample information so that necessary preparations can be made for the school records collections. See PWS pages 10 and 34 about government furnished information.

4 Will district approvals for data collection allow collection of updated name and address information?

The Department anticipates that updated contact information (i.e., directory information) will be obtained as part of the school records collection.

5 On page 9 of Attachment A, the first paragraph of 3.1 says to see Appendix A for additional information about SSA matching?

Where is it?

Appendix A is included as an attachment to these clarification questions and responses.

6 If a project for past performance is in CPARS or PPIRS, does a complete reference form still need to be submitted?

The intent is for offerors to provide evidence of prior successful work as described in the solicitation and for references to provide past performance information by completing Attachment C, Contractor Past Performance Information. Per Section L.16, Instructions to Offerors, the Department reserves right to obtain

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past performance information from other sources such as the Contractor Performance Assessment Reporting System (CPARS), and Past Performance Information Retrieval System (PPIRS).

7 Can the department please provide a word version of attachment C, past performance evaluation form? We find this makes it easier for the person completing the form to complete and submit it.

A word version of Attachment C is included as an attachment.

8 Can letters of commitment be placed in an appendix?

Per Section L.16, Instructions to Offerors, letters of commitment are to be included in the technical proposal.

9 Are tasks 12, 13, 17, and 18 firm fixed price (FFP) or cost reimbursement (CR) tasks? In the RFP, these tasks are listed as FFP in the task-by-task descriptions but as CR in the up-front schedule and in the PWS schedule of deliverables.

Tasks 12, 13, 17, and 18 are cost reimbursement tasks. The corrected version of the PWS is included as an attachment to these clarification questions and responses.

10 The RFP’s deliverables timeline, page 71 of the RFP, says that draft materials for second round data collection (task 9.1) are due by week 48, which is 08/26/16. This date occurs before option period one when the second data collection is scheduled. Can ED clarify the due date for the draft materials.

Draft materials for second round data collection (task 9.1) are due by week 94 (or 6 weeks after Option Period II begins). The corrected PWS version includes the updated date for the task 9.1 deliverable.

11 Can the past performance report be included as an appendix to the technical proposal or should it be in its own separate volume?

Past Performance information is to be included as part of the technical proposal. Per Section L.16, Instructions to Offerors, technical proposals include “examples of previous work.”

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Attachment A (Updated 7/1/2015)

Performance Work Statement

POST HIGH SCHOOL OUTCOMES FOR YOUTH WITH DISABILITIES

National Center for Education Evaluation and Regional Assistance Institute of Education Sciences

U.S. Department of Education

I. INTRODUCTION

The Institute of Education Sciences (IES) at the U.S. Department of Education (ED) requires a contract to collect administrative records and describe the secondary school, postsecondary education, and employment and earning outcomes of a sample of high school youth with disabilities.

A. Period of Performance

The 60-month contract is comprised of a base period of 30 months and three overlapping options periods. The 30-month Base Period will focus on collection and analysis of high school and early college outcomes. Option Period 1, spanning 40 months, will focus on conducting a second-round collection of secondary and postsecondary education records and updating the analysis of high school and early college outcomes from the Base Period. Option Period 2, covering 16 months, will focus on conducting a first-round collection of records from the Social Security Administration (SSA) and an analysis of employment and earning outcomes. Option Period 3, spanning 30 months, will focus on completing a second-round collection of SSA records and updating the analysis of employment and earning outcomes from Option Period 2.

Table 1. Post High School Outcomes for Youth with Disabilities Periods of Performance

Contract Period Purpose Start End

Total Duration in Months

Base Period

Collect and report on high school and early college outcomes Month 1 Month 30 30 months

Option Period 1 (with optional tasks 7-11) 1

Collect second round of and update report on high school and early college outcomes Month 20 Month 60 40 months

Option Period 2 (with optional tasks 12-16)

Collect and report on post-high school employment and earnings Month 20 Month 36 16 months

1 The Option Period’s period of performance is not affected by whether or not optional tasks are exercised. For example, the period of performance for Option Period 1 remains the same 60 month period regardless of whether all optional tasks are exercised.

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Option Period 3 (with optional tasks 17-21) 2nd round SSA collection Month 30 Month 60 30 months

B. Legislative Authority

This work is authorized in Section 664 of the 2004 amendments to the Individuals with Disabilities Education Act (IDEA), which requires IES to conduct the National Assessment of

IDEA.

C. Background

The most recent reauthorization of the Individuals with Disabilities Act (IDEA) in 2004 (P.L.108-446) continued federal legislation and support for educating children with disabilities that stretches back to the 1960’s. IDEA 2004 mandates that all children with disabilities receive a “free appropriate public education” (FAPE), through special education and related services, designed to prepare them for further education, employment, and independent living. Taken together with the 1990 Americans with Disabilities Act (including the Ticket to Work and Work Incentives Improvement Acts) and new disability provisions in the 1998 Workforce Investment Act and its successor in 2014, these federal policies have placed an increased emphasis on preparing youth with disabilities for postsecondary education and employment.

ED is interested in better understanding how students attending school since enactment of IDEA 2004 may be experiencing these important outcomes. In 2011, there were more than 2.7 million youth with disabilities (ages 13-21), accounting for 12 percent of all secondary school-age youth in the United States.2 Previous studies of youth with disabilities sponsored by ED, including the National Longitudinal Transition Study (NLTS) launched in 1987 and the National Longitudinal Transition Study 2 (NLTS-2) begun in 2001, highlighted the diversity of experiences these earlier students had during and after high school. In addition, NLTS and NLTS-2 showed youth with disabilities had increased rates of high school completion and participation in postsecondary employment and education (Wagner, Newman, Cameto,& Levine, 2005; Wagner, Cameto, & Newman, 2003). Updated information on current students would allow for assessment of whether these promising trends are continuing.

This new study of post-high school outcomes for youth with disabilities will build on work currently being completed to survey a recent cohort of such youth. ED is finishing Phase 1 of the National Longitudinal Transition Study 2012 (NLTS 2012), which follows in the tradition of NLTS and NLTS 2. 3 NLTS 2012 Phase 1 differs from the early stages of previous studies of

2 Based on state-reported data. See available IDEA data available at http://tadnet.public.tadnet.org/pages/712 and Common Core Data available at http://nces.ed.gov/ccd/..

3 Contract #ED-IES-10-C-0073 was awarded to Mathematica in September 2010 to conduct Phase I of

NLTS2012. As part of Phase I, a technical report and restricted-use data file is anticipated to be released by the end of 2015. Reports will be released through the Institute of Education Sciences (IES) website at http://ies.ed.gov/ncee/.

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youth with disabilities in important ways. First, in addition to collecting information on a nationally-representative sample of youth with disabilities, NLTS 2012 also collected information on a representative but small sample of youth without an individualized educational program (IEP) that included youth who do not have an IEP but are qualified for accommodations under Section 504 of the Vocational Rehabilitation Act of 1973; including youth without IEPs in the sample allows for direct comparisons in ways that have not previously been possible.

However, because of cost constraints, NLTS 2012 Phase 1 included only one round of survey collection while students were in high school, and no academic assessment. The requirements in this performance work statement represent Phase 2 of NLTS 2012, which is also different from the previous studies in that it relies entirely on administrative records collection. Use of administrative records is less costly, produces more reliable outcomes information than self-reporting through surveys of youth, and is a more viable option now than in the past by matching with other organizations’ databases.

II. OVERVIEW OF THE STUDY

The main objective of the study is to collect existing administrative records in order to follow the NLTS 2012 sample of youth with disabilities and to describe the secondary school, postsecondary education, and employment and earning outcomes for this cohort of youth.

Multiple waves of data collection will ensure that key outcomes are available for even the youngest students in the sample and allow for assessment of both early and later post-high school experiences for some youth.

A. Key Research Questions

The components of this requirement will address the following major questions:

• To what extent do youth with disabilities make progress through high school compared to other youth, including those identified for services under Section 504 of the Rehabilitation Act? To meet the objectives of IDEA and to prepare for further education, employment, and independent living, students might be expected to take academic and/or career-and-technical (CTE) courses, attend school regularly, meet their state’s benchmark for academic proficiency, and graduate with a high school credential. Through the Base Period and Option Period 1, NLTS 2012 Phase 2 will examine the course taking and attendance patterns of youth with and without disabilities, their performance on state academic assessments, and their attainment of regular and alternative high school diplomas. These measures, combined with information from the Phase 1 surveys, will provide a more complete and updated picture of how students make their way through secondary school. Trends in high school course taking, behavior, and completion will be assessed because data collected for the NLTS 2012 is sufficiently similar to that collected for the earlier NLTS studies.

• Are youth with disabilities achieving the post-high school outcomes envisioned by IDEA, and how do their college, training, and employment rates compare to those of other youth? Given the increasingly important role postsecondary education plays in determining lifetime income and the policy emphasis on some kind of postsecondary

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credential for all, it is important to assess whether students with disabilities are enrolling, persisting in, and completing postsecondary educational programs. The work in the Base Period and Option Period 1 will examine attainment of these outcomes, and the financial aid and high school experiences of students who do and do not achieve them. Since working and having sufficient resources for living is key to long-term independence, NLTS 2012 Phase 2 Option Periods 2 and 3 seek to describe eligibility for federal supplemental income benefits, participation in vocational rehabilitation services, and early employment and earnings in the few years before and after leaving secondary school.

• How do these high school and postsecondary outcomes vary with student characteristics, including their disability category, age, sex, race/ethnicity, English Learner status, income status, and type of high school attended (including regular public school, charter school, career/technical school, special education school, or other State or Federally-operated institution)? Previous research from NLTS and NLTS 2 highlighted the diversity in pathways through and after secondary school for students with different backgrounds. NLTS 2012 Phase 2 will similarly examine the variation in key outcomes across groups.

B. Sources of Data

This study will require obtaining information from the following data sources. Table 2 includes estimated sample sizes for each data source.

Sample Information for NLTS2012. ED will provide the contractor with information for the NLTS2012 sample of 21,959 youth in order to conduct this study, including their consent status, study ID, school attended, and district approvals for data collection.

NLTS, NLTS2, & NLTS2012 Restricted-use Data Files. NLTS2012 RUF includes survey data collected from parents and youth including, but not limited to, characteristics of youth, their school and work experiences, post-school expectations, and transition planning. The contractor shall obtain restricted-use licenses for the NLTS2012 data file in a timely manner to allow for prompt preparations for the study. Additionally, the contractor must independently obtain restricted-use licenses for the original National Longitudinal Transition Study (NLTS) and the National Longitudinal Transition Study 2 (NLTS2) in order to conduct comparisons over time.4

Transcripts and Other School Records. The contractor will be responsible for preparing for and conducting school records collection from the 430 school districts that participated in NLTS2012. Collection of school records will include obtaining information on statewide 8th grade and high school state assessment scores, dates of enrollment, attendance, suspensions, 4 Only certain NLTS2012 data may be compared with data from the two prior NLTS studies – specifically high school course-taking and completion. As noted in the Background section (p. 3), NLTS 2012 Phase II is designed to rely on certain types of administrative records collection, unlike prior NLTS studies.. Because of differences in the sources of data, ED does not believe it would be possible to compare the other outcomes across studies.

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expulsions, whether a youth completed high school, and, if so, the type of credential earned.

Collection will also include obtaining and coding high school transcripts that contain information on courses, credits, and grades. As part of this collection, the contractor will determine, through school course catalogs and/or by asking districts, which courses are self-contained special education courses and honors/AP courses. The contractor will obtain school records that cover student experiences through School Year (SY) 2014-15 during the base period, for most if not all of the NLTS2012 sample of 21,959 youth (some students will only have partial data available since they will still be in school). The second round of school records collection (Option Period 1), will cover school experiences through SY 2017-18 and focus on the approximately 6,000 youth in the sample who are expected to have either completed or left high school after the initial round of records collection.

National Student Clearinghouse Records. The National Student Clearinghouse (NSC) records include information on postsecondary school enrollment and participation, and where applicable, degree completed. NSC can extract records from the system it maintains using only name, address, and date of birth, data considered “directory information” and that can be shared under federal privacy provisions.5 In addition to preparing a file to extract NSC records during the base period (for SY2012-13 through SY2014-2015), an optional second round of extraction (Option Period 1) is planned for Fall 2018.

Federal Student Aid Records. ED’s Office of Federal Student Aid (FSA) records include, but are not limited to, information on youth’s application for and receipt of financial aid to support postsecondary education. FSA can extract data from its system using directory information. In addition to preparing a file for FSA records extraction during the base period, an optional second round of records extraction (Option Period 1) is planned for Fall 2018.

Social Security Administration Records. The SSA records consist of information including but not limited to (1) annual employment and earnings information from the Master Earnings File (provided to ED only in tabular form or at aggregated group levels); (2) Supplemental Security Income (SSI) and Disability Insurance (DI) beneficiary information, including type of benefit, amounts, start of benefit receipt, demographic and impairment characteristics; (3) Vocational Rehabilitation participation information, including application, service use, employment status and income sources; and (4) Medicaid eligibilty, types and dates of service, and payments.

Under standard procedures, the SSA records are not accessible for NLTS 2012 because NLTS 2012 did not collect individual Social Security Numbers (SSNs). Under an MOU to be established between ED and SSA, SSA may be able to use directory information as a conduit to SSNs on its internal files so that data originating at SSA and at the Rehabilitation Services Administration but linked to SSA records, can be extracted and/or tabulated for NLTS 2012 use6.

Discussions with SSA are still underway and the matching procedure has not been verified.

5 The Family Educational Rights and Privacy Act (FERPA; 20 U.S.C. § 1232g; 34 CFR Part 99) 6 Some information contained in SSA records, specifically annual earnings, cannot be provided back to data requesters at the individual level. ED is interested in exploring whether it will be possible to have SSA compute “micro-averages” for groups of NLTS 2012 sample members that could then be used by the contractor for tabulations. Alternatively, SSA will need to tabulate the data and provide results back to ED and the contractor.

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Should this approach prove feasible, a first round of data extraction (Option Period 2) is planned for Summer 2017, and an optional second round (Option Period 3) is planned for early 2019.

Table 2. Post-High School Outcomes for Youth with Disabilities Study Key Data Sources Data Source Data Years Estimated Sample Key Data

NLTS2012 sample information

NA 21,959 Sample and contact information

NLTS 2012 restricted-use data file

Parent Survey 2012-2013 12,988 Characteristics of youth and household, school experiences, post-school expectations, disabilities and functional abilities, transition planning

Youth Survey 2012-2013 11,128 Experiences and perceptions in school, experiences outside of school, work experiences, post-school expectations, self-determination, independence

School Districts Records Each Fall 2014 - 2018

19,651 Enrollment, attendance, 8th grade and high school state test scores, suspensions, expulsions, whether graduated, type of high school credential, transcripts (courses taken, whether courses are self-contained special education courses, credits earned, grades)

National Student Clearinghouse

Each Fall 2014 - 2018

19,056 Post-secondary institutions attended, enrollment dates, degree completions

Federal Student Aid Each Fall 2014 - 2018

19,056 Type of financial aid received, amount of aid received

Social Security Each Fall 3,495 7 Employment status, 7 The estimated sample for SSA records includes the number of NLTS2012 sampled youth for whom explicit consent had been obtained under Phase I at the time permission was obtained from parents to survey them and the sampled youth.

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Administration (optional) 2014 - 2018 earnings, Vocational Rehabilitation services (e.g., counseling services, psychological services, vocational job training, medical services, supported employment), and Medicaid eligibility and services.

II. SCOPE OF WORK

This section specifies the tasks and subtasks that the contractor shall perform.

A. Obtaining and reporting on information about high school coursework, completion, and early post-high school education and training (BASE from 9/16/2015-12/15/201)

Task 1 – Communicate with ED (Cost Reimbursement Task)

1.1 Kick-off Meeting. The contractor’s project director and key project staff (up to two) shall meet with the COR and other appropriate ED staff in Washington, DC within ten working days of the effective date of the contract award to discuss details regarding the tasks outlined in the proposal and other issues related to the contract. The contractor shall provide an updated schedule of activities and deliverables, an agenda for the meeting and come prepared to identify any areas of concern and to suggest ways of responding to these concerns. Within one week of the meeting, the contractor shall submit to the COR a memo summarizing the key issues and concerns raised at the meeting, and how each will be addressed, as well as any proposed updates to the plans and schedule.

1.2 Periodic Meetings. The contractor shall be available for biweekly conference calls, if requested by ED, to discuss the progress of the studies under this contract, including any anticipated problems and proposed solutions to those problems.

In addition to meetings by phone, the contractor shall also be prepared to participate in up to two in-person meetings with ED staff to be scheduled as requested by ED during the course of the base period. The purpose of the meetings is to brief ED on the progress of the study and to discuss issues as they arise.

Within two working days of each call (or in-person meeting), the contractor shall submit to the COR a brief summary of the key issues and concerns discussed along with the contractor’s understanding of the COR’s technical direction.

Deliverables: Memo summarizing the kick-off meeting

Summaries of telephone calls (or in-person meetings)

Task 2 – Technical Work Group (TWG) (Cost Reimbursement Task)

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2.1 Establish Expert Panel. This expert panel shall be composed of consultants who advise the contractor on issues related to the conduct of the study, including but not limited to the data collection, methods, analysis, and reporting. The panel shall include up to eight individuals with expertise in secondary and postsecondary education for youth with disabilities, knowledge of and experience using the relevant administrative records, expertise in research methodology and analytic strategies for descriptive studies. The contractor shall submit to the COR a list of proposed panelists and a summary of their expertise within ten working days of the effective date of the contract (for discussion at the kick off meeting—Task 1.1-Kick-Off Meeting). When preparing the list, the contractor shall evaluate the potential for conflicts of interest by assessing whether each potential panel member has a bias or financial interest in the outcome of the study.

After the proposed panel members are approved by the COR, the contractor shall contact each approved potential panelist to obtain their agreement to participate within six weeks of the effective date of the contract.

2.2 Convene Expert Panel. The contractor shall convene one meeting of the panel during the base period of the contract. Meeting sites shall be arranged in Washington, DC, convenient to Federal government staff members. The contractor shall cover the travel, per diem, and honorarium expenses of the TWG members. The costs of working lunches will be deducted from each TWG member’s per diem and shall be provided only for those who are on travel status. ED staff shall participate in these meetings, as appropriate, and meetings shall be held in ED facilities in the Washington, DC area.

The objective of the meeting convening the expert panel will be to discuss preliminary findings on high school and early college outcomes (related to work in Task 7) and the options for matching with and utilizing SSA records (from Task 3). The meeting will also include discussion of analysis and reporting plans for additional data to be collected, if ED decides to pursue a second round of school and NSC records collection. The contractor, in conjunction with the COR, shall decide upon the timing of the meeting, but the meeting should occur no later than 75 weeks after the effective date of the contract.

No later than six weeks before the meeting, the contractor shall submit to the COR draft materials for the meeting, including an agenda, presentation materials, and other materials for the panel’s review not already covered in other tasks. The COR will review and comment within two weeks. The contractor shall make revisions in response to COR comments and submit final materials to the COR no later than three weeks before the meeting. After COR and IES approval, and no later than one week before the meeting, the contractor shall send the approved materials to the panel members. After the meeting, the contractor shall submit a written summary of the meeting to the COR within one week, detailing suggestions and recommendations along with the contractor’s proposed actions. The contractor shall not go forward with any panel recommendations or proposed actions unless approved by the COR.

The contractor also shall use the panel members to review products, as appropriate, when group meetings are not required. The contractor shall provide copies of all comments received from members of the panel to the COR within five work days of receipt by the contractor. The contractor shall not make changes based solely on the recommendations or comments of the panel members without COR approval.

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The COR must approve all correspondence with the expert panel members before the contractor may send the correspondence.

Deliverables: List of proposed panelists Letters of commitment

Draft panel meeting materials Final panel meeting materials

Summary of panel meeting

Task 3 – Assessing Options for Obtaining and Using SSA Records (Cost-Reimbursement Task)

3.1 Finalizing plans for assessing options. The contractor shall expand on and refine the plans submitted in the proposal in response to further information ED obtains from SSA and other issues discussed during the kick-off meeting. The contractor shall discuss the overall objectives and plans to assess feasibility for obtaining SSA records and design options for SSA records collection. Subtask 3.1 also includes determining the status of the MOU with SSA and specific plans to work with SSA on the pilot testing of matching with SSA files. See Appendix A for additional information about SSA matching.

The contractor shall submit revised plans to the COR no later than 2 weeks after the kick-off meeting (Subtask 1.1). The COR will review the revised plans within two weeks. The contractor shall make revisions and submit final study plans to the COR no later than 8 weeks after start of contract. The final plans shall be fully responsive to COR comments. The contractor must request, in writing, ED approval for any subsequent changes to the approved plans. If approved, the contractor must then revise the approved final plan document to incorporate the approved changes.

3.2 Pilot Test of Matching with SSA files. The contractor shall develop the materials for and be available to answer questions from SSA for the pilot test of linking NLTS2012 sample members to SSA’s administrative data files. The process for pilot testing and collection of SSA data will differ from other records collection activities. The contractor will prepare a data file containing directory information for the sample and all data items from the NLTS 2012 Phase I survey necessary to conduct the pilot matching with SSA’s files.

3.3 Develop Options Memo for SSA Records Collection. The contractor, in consultation with the COR, shall develop options for SSA records collection. The memo will build on the plans submitted in the contractor’s original proposal and synthesize results from the pilot matching, anticipated number of NLTS2012 sample members with consent for matching and the expected rates of matching, and the types of data that could be obtained and used for analysis. The memo shall provide multiple options for obtaining and using SSA records with the pros and cons of each option. The contractor shall submit a draft memo 12 weeks prior to the TWG briefing or no later than 62 weeks after the effective date of the contract, whichever comes sooner. ED will review the draft memo within two weeks. The contractor shall submit a revised memo no later than eight weeks before the TWG meeting. ED will expect the revised memo to be fully responsive to COR comments.

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Deliverables: Revise study plans

Final study plans Draft options memo

Revised options memo

Task 4 –Collection of District, NSC, and FSA Records (Cost-Reimbursement Task)

4.1 Acquire NLTS2012 Phase I Sample Files and Other Knowledge. As described earlier, the work in this contract will follow a cohort of youth sampled for NLTS2012 Phase I data collection (EDIES10C0073). Within 2 weeks following the kick-off meeting (Task 1), it will be critical for the contractor to obtain information from the COR for the NLTS2012 Phase I sample of 21,959 youth, including their consent status, study ID, school attended, and district approvals for data collection.

4.2 Planning and Approvals for School District, NSC, and FSA Records Collection. The contractor shall submit draft materials, including documents for required approvals (e.g., IRB), for records collection in accordance with the OMB-approved information collection package to the COR no later than 4 weeks after kick-off meeting (Subtask 1.1).8 For district record collection, planning activities may also include obtaining MOUs from districts not already obtained during Phase I of NLTS2012 and other required approvals, as needed.9 District records collection will include information on statewide 8th grade and high school state assessment scores, dates of enrollment, attendance, suspensions, expulsions, whether a youth completed high school, and, if so, the type of credential earned. Collection will also include obtaining high school transcripts, which will include information on courses, credits, and grades, and, to the extent possible, course catalogs for the years covered by the transcripts. As part of this collection, the contractor will ask districts to designate which courses are/were self-contained special education courses and honors/AP courses.

Preparation for NSC records collection will include developing drafts of an MOU or a subcontract with NSC in addition to other materials required for extraction of the data. NSC records to be obtained include initial and ongoing enrollment in postsecondary institutions and, where available, declared major (including the CIP code), full-time vs. part-time status, and degree completion. Planning for FSA records collection will include developing a file of sample members that the COR will provide to FSA, and a list of variables from FSA’s National Student Loan Data System (NSLDS) that are relevant for analysis under this contract. Variables from NSLDS that are relevant for analysis under this contract, include but are not limited to completion of the Free Application for Federal Student Aid (FAFSA) and the data contained on the FAFSA, the schools to which students sent their FAFSA data, and whether a student received a Pell grant or other federal aid (loans, work study, etc).

8 OMB approval will have been obtained by ED prior to the start of the study. Therefore, a task for OMB package submission activities have not been included as part of the study.

9 Of the 430 districts that participated during the Phase I data collection, MOU’s and/or research agreements were obtained from 413 districts (398 MOU’s and 15 approved research applications).

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The COR will review submitted draft materials within two weeks. The contractor shall incorporate ED-approved revisions to draft materials. The contractor shall ensure that materials are revised as needed to ensure successful records collection and will submit revised materials no later than 8 weeks after the kick-off meeting (Subtask 1.1). The contractor shall submit documentation of required approvals (e.g., district MOUs, IRB approvals, NSC subcontract/MOU) by 16 weeks after award (or by no later than the start of records collection).

The contractor must request, in writing, ED approval for any subsequent changes to the plans.

4.3 Ensuring Data Security and Confidentiality. Prior to the start of records collection, the contractor shall develop a process for monitoring the flow of data collection activities. This process shall permit the contractor to track the status of all collection activities. To ensure that data collected are of high quality, the contractor shall have a process in place for quickly identifying patterns of inaccuracies and anomalies in the data (such as out-of-range variables, missing data, and unusual distributions of scores), such that immediate corrective action can be initiated. All such problems and subsequent corrections must be carefully documented and compiled into a technical report that shall be included with the final archived data set.

The contractor, and all sub-contractors, shall comply with the Department of Education’s IT security policy requirements, specifically those set forth in the ‘Handbook for Information Assurance Security Policy (OCIO-01)’, and other applicable procedures and guidance. The contractor, and all sub-contractors, shall develop and implement management, operational and technical security controls to assure required levels of protection for information systems. The contractor, and all sub-contractors, shall further comply with all applicable Federal IT security requirements including, but not limited to, the Federal Information Security Management Act (FISMA) of 2002, Office of Management and Budget (OMB) Circular A-130 Appendix III, Homeland Security Presidential Directives (HSPD), the National Institute of Standards and Technology (NIST) standards and guidance, and the Federal Risk and Authorization Management Program (FedRAMP) requirements and guidance.

These security requirements include, but are not limited to, the successful Security Authorization (SA) of the system (includes commercially owned and operated systems managed by the commercial vendor and its sub-contractors, supporting Department programs, contracts, and projects); obtaining a full Authority to Operate (ATO) before being granted operational status;

performance of annual self-assessments of security controls; annual Contingency Plan testing;

performance of periodic vulnerability scans; updating all information system security documentation as changes occur; and other continuous monitoring activities, which may include, mapping, penetration and other intrusive scanning. Full and unfettered access for the Department’s third party, Managed Security Services Provider (MSSP), must be granted to access all computers and networks used for this system. Additionally, when there is a significant change to the system’s security posture, the system (Federal and commercial prime- and sub-contractors included) must have a new SA, with all required activities to obtain a new ATO, signed by the Authorizing Official (AO).

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System security controls shall be designed and implemented consistent with NIST SP 800-53 Rev 3, ‘Recommended Security Controls for Federal Information Systems and Organizations.’ 10 All NIST SP 800-53 controls must be tested/assessed no less than every 3 years, according to federal and Department policy. The risk impact level of the system will be determined via the completion of the Department's inventory form and shall meet the accurate depiction of security categorization as outlined in Federal Information Publishing Standards (FIPS) 199, ‘Standards for Security Categorization of Federal Information and Information Systems.’

System security documentation shall be developed to record and support the implementation of the security controls for the system. This documentation shall be maintained for the life of the system. The contractor, and all sub-contractors, shall review and update the system security documentation at least annually and after significant changes to the system, to ensure the relevance and accurate depiction of the implemented system controls and to reflect changes to the system and its environment of operation. Security documentation must be developed in accordance with the NIST 800 series and Department of Education policy and guidance.

The contractor, and all sub-contractors, shall allow Department employees (or Department designated third party contractors) access to the hosting facility to conduct SA activities to include control reviews in accordance with NIST SP 800-53, Rev. 3 and NIST SP 800-53A. The contractor, and all sub-contractors, shall be available for interviews and demonstrations of security control compliance to support the SA process and continuous monitoring of system security. In addition, if the system is rated as ‘Moderate’ or ‘High’ for FIPS 199 risk impact, vulnerability scanning and penetration testing shall be performed on the hosting facility and application as part of the SA process. Appropriate access agreements will be reviewed and signed before any scanning or testing occurs.

Identified deficiencies between required NIST SP 800-53 Rev. 3 controls and the contractor’s, and all sub-contractor’s implementation, as documented in the Risk Assessment Report, System Security Plan (SSP) and Security Assessment Report (SAR), shall be tracked for mitigation through the development of a Plan of Action and Milestones (POA&M) in accordance with the ‘Handbook for Information Assurance Security Policy (OCIO-01).’ Depending on the severity of the deficiencies, the Department may require remediation before an ATO is issued.

All awarded contracts shall ensure that:

1. Their IT product/system is monitored during all hours of operations using entrusted detective/preventive systems;

2. Their IT product/system has current antiviral products installed and operational;

3. Their IT product/system is scanned on a reoccurring basis;

4. Vulnerabilities are remediated in a timely manner on their IT product/system; and

10 Note that compliance with NIST SP 800-53 Rev. 4 will be required starting September 2015, replacing the requirement to comply with Rev. 3.

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5. Access/view for cyber security situational awareness on their IT product/system is made available to the Department CIRC (cyber incident response capability).

For IPv6, the contractor shall provide COTS solutions that are IPv6 capable. An IPv6 capable system or product shall be capable of receiving, processing, transmitting and forwarding IPv6 packets and/or interfacing with other systems and protocols in a manner similar to that of IPv4.

Specific criteria to be deemed IPv6 capable are:

• An IPv6 capable system that meets the IPv6 base requirements defined by the USGv6 Profile and Testing program as found at http://w3.antd.nist.gov/usgv6/testing.html.

• Systems being developed, procured or acquired shall maintain interoperability with IPv4 systems/capabilities.

• Systems shall implement IPv4/IPv6 dual-stack and shall also be built to determine which protocol layer to use depending on the destination host it is attempting to communicate with or establish a socket with. If either protocol is possible, systems shall employ IPv6.

The contractor shall provide IPv6 technical support for system development, implementation and management. Information systems shall be developed in accordance with the ED Lifecycle Management Framework (LCM), ACS-OCIO 1-106.

The contractor shall ensure that all data in a computerized form shall be suitable for data editing and corrective actions consistent with the U.S. Department of Education’s Information Quality Guidelines (http://www2.ed.gov/policy/gen/guid/iq/iqg.html) in order to provide for quality control of data entry and yielding verified and accurate records.

The contractor, as appropriate, shall comply with: The Privacy Act of 1974, P.L. 93-579, 5 USC 552 a 11; the “Buckley Amendment,” Family Educational Rights and Privacy Act of 1974, 20 USC 1232 g 12; The Freedom of Information Act, 5 USC 522 13; and related regulations, including but not limited to: 41 CFR Part 1-1 and 45 CFR Part 5b and, as appropriate, the Federal common rule or ED’s final regulations on the protection of human research participants.14

11 Available at http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title5-section552a&num=0&edition=prelim 12 Available at http://uscode.house.gov/view.xhtml?req=20+USC+1232g&f=treesort&fq=true&num=14&hl=true&editio n=prelim&granuleId=USC-prelim-title20-section1232g 13 Available at http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title5-section552&num=0&edition=prelim 14Information for the U.S. Department of Education available at http://www2.ed.gov/about/offices/list/ocfo/humansub.html

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The contractor shall be required to establish procedures at its sites and at subcontractor sites to ensure confidentiality of data. Their systems shall be required to provide reasonable assurance that information identifying individuals is in files physically separated from other research data.

The contractor and subcontractors shall be required to maintain security of the complete set of all master data files and documentation. Access to individually identifiable data shall be strictly controlled. At each site all data shall be kept in locked file cabinets during nonworking hours, and work on hardcopy data shall take place in a single room, except for data entry. Physical security of electronic data shall also be maintained. Security features that protect project data shall include password-protected accounts that authorize users to use the contractor’s and subcontractors’ information systems but only to access specific network directories and network software; user rights and directory and file attributes that limit those who can use particular directories and files and determine how they can use them; and, additional security features that the network administrators establish for projects as needed. Contractor and subcontractor employees who “maintain” (collect, maintain, use, or disseminate) such data shall comply with the requirements of the confidentiality standards in section 183 of the Education Sciences Reform Act (20 U.S.C. 9573).

In safeguarding personally identifiable information (PII), the contractor and its subcontractors shall be subject to ED’s requirements contained in ED’s Handbook for the Protection of Sensitive But Unclassified Information, OCIO-15,15 and ED’s policy that the transmission of sensitive but unclassified information, including PII, through an e-mail requires that the contents be password protected in a ZIP file. All persons who collect, code, or otherwise have access to raw data must be trained in confidentiality issues and shall provide signed assurances of nondisclosure of confidential information. The Contractor shall maintain these records and provide them to the Government upon request.

If there is a suspected or known breach/disclosure of PII due to loss, theft, intercepted transfer, or other, the contractor must ensure that this breach is reported to ED as soon as the contractor has knowledge of it. Per Office of Management and Budget Memorandum M-06-19, Federal agencies have a requirement to report breaches of PII security to a Federal incident response center. IES/NCEE must notify ED within 30 minutes of discovering the incident (and the agency should not distinguish between suspected or confirmed breaches). The data security plan must be written to reflect this requirement, and the contractor must provide sufficient notification and documentation of the suspected loss, as it is understood at the time of notification to the agency for this requirement to be met. Follow-up reports of the final status of loss events will also be prepared by the contractor within a reasonable period of time as advised by the ED/IES COR.

4.4 Collect School District, NSC, and FSA records. Using plans approved by ED and OMB, the contractor shall collect data to answer the key research questions.16 The contractor will be responsible for data collection and storage, as required by IES and following procedures that meet the requirements specified below.

15 OCIO resources are available at http://www2.ed.gov/fund/contract/about/bsp.html 16 OMB approval will have been obtained by ED prior to the start of this study.