Draft_Performance_Work_Statement_4_23_2015.docx

DRAFT 4/23/2015

DRAFT 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) intends to award 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 Contract Periods

Option Period 1 (with optional tasks 7-11) [footnoteRef:1] [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.]

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.[footnoteRef: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. [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/..]

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. [footnoteRef:3] NLTS 2012 Phase 1 differs from the early stages of previous studies of 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. [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/.]

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 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.[footnoteRef:4] [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. ]

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, 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.[footnoteRef: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. [5: The Family Educational Rights and Privacy Act (FERPA; 20 U.S.C. § 1232g; 34 CFR Part 99)]

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 use[footnoteRef:6]. Discussions with SSA are still underway and the matching procedure has not been verified. 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. [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.]

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

NLTS 2012 restricted-use data file

Employment status, 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)

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.

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

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.

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).[footnoteRef: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.[footnoteRef: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. [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). ]

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).

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).

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.’ [footnoteRef: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.’ [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. ]

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

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 [footnoteRef:11]; the “Buckley Amendment,” Family Educational Rights and Privacy Act of 1974, 20 USC 1232 g [footnoteRef:12]; The Freedom of Information Act, 5 USC 522 [footnoteRef: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.[footnoteRef: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&edition=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] [14: Information for the U.S. Department of Education available at http://www2.ed.gov/about/offices/list/ocfo/humansub.html]

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,[footnoteRef: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. [15: OCIO resources are available at http://www2.ed.gov/fund/contract/about/bsp.html]

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.[footnoteRef:16] The contractor will be responsible for data collection and storage, as required by IES and following procedures that meet the requirements specified below. [16: OMB approval will have been obtained by ED prior to the start of this study. Therefore, a task for OMB package submission activities are not included as a part of this study.]

The contractor shall collect school district, NSC, and FSA records, following the OMB-approved plan for records collection (Task 4), starting no later than 16 weeks after the effective date of the contract. The contractor shall complete the collection of records data no later than 31 weeks after the effective date of the contract, utilizing strategies to obtain the maximum number of records for NLTS2012 sampled youth. The contractor shall submit biweekly updates on the status of the data collection to the COR during each period of data collection.

4.5 Transcript coding. The contractor shall prepare and code high school transcripts after obtaining district designations of which courses are self-contained special education courses and honors/AP courses. The contractor shall code according to the NCES secondary school taxonomy (SST), utilizing cost effective approaches and specialized software as needed. The contractor shall complete coding of transcripts no later than 49 weeks after the effective date of the contract. The contractor shall submit biweekly updates, along with data collection updates, on the status of coding to the COR.

Draft FSA records collection materials Revised school district records collection materials

Biweekly records collection and transcript coding updates

Task 5 – Analysis and Reporting (Cost-Reimbursement Task) Following school district, NSC, and FSA records collection, the contractor shall conduct data analysis and prepare a report addressing the key research questions relating to high school progress, completion and postsecondary enrollment. Additionally, the report will include comparisons across NLTS cohorts (NLTS, NLTS2, NLTS2012) to examine trends in high school course-taking and completion.

5.1 Draft and Revised Analysis Plan. Prior to conducting analyses, the contractor shall draft a preliminary analysis plan. In the plan, the contractor shall discuss the proposed analyses in detail. In the plan, the contractor shall include at a minimum, but not be limited to:

· Introduction and Study Overview, including study background, research questions relevant to the report, summary of study design, including sample. [footnoteRef:17] [17: The introduction will include a brief description of the NLTS2012 Phase I study as well as the Phase II study design for following the NLTS2012 sampled youth utilizing administrative records. ]

· Variables, including description of the data collection procedures, description of the proposed analytic variables and constructs and how they were derived (reliability and validity information, as necessary).

· Analysis Procedures, including sample size flowcharts showing flow between NLTS2012 sample and follow up records; data variables to be used in analyses to address key research questions, including comparable variables available across the three NLTS cohorts; plan for handling missing data and/or sample attrition; discussion of any weighting to be applied; use of statistical testing; proposed table and figure shells.

· Annotated Report Outline.

The contractor shall submit the draft analysis plan to the COR within 30 weeks after the effective date of the contract. The COR and members of the expert panel will review the draft analysis plan within three weeks. The contractor shall make revisions and submit a revised analysis plan to the COR within 36 weeks after the effective date of the contract. The revised analysis plan shall be fully responsive to COR comments on the draft plan.

The contractor must request, in writing, ED approval for any subsequent changes to the approved analysis plan. If approved, the contractor must then revise the approved final analysis plan document to incorporate the approved changes.

5.2 Analyze Data and Brief IES. Using the ED-approved analysis plan, the contractor shall conduct data analyses to address the research questions. The contractor shall submit draft PowerPoint slides for use at a briefing for IES to the COR within 64 weeks after the effective date of the contract. The COR will review the slides within two weeks of receipt. The contractor shall incorporate comments in making revisions and shall be fully responsive to COR comments on the slides. The contractor shall use the revised slides to brief the COR and other appropriate ED staff on the preliminary findings in Washington, DC by no later than 71 weeks after the effective date of the contract. In the briefing presentation slides, the contractor shall briefly summarize the study design and analysis plan, and present preliminary findings addressing the relevant research questions. The contractor shall also briefly summarize the results from the SSA pilot test of matching procedures and the options for obtaining and utilizing SSA records (Task 3).

5.3 Prepare Report. The contractor shall prepare a report that clearly addresses the research questions and addresses IES and TWG comments from the briefing of preliminary findings. The contractor shall ensure that the study report is well-conceptualized and written so that it is easily accessible to a non-technical audience of policy makers and research-savvy practitioners. The report shall be (1) well-motivated, concise, and policy-relevant and (2) convey complex technical information using plain language and, to the extent possible, figures and charts. The report shall include the use of user-friendly tables, graphs, and figures that convey information accurately and sufficiently, and that explicitly label the outcomes being presented. The report shall also include a detailed description of methodology, how the data collection instruments were developed and refined, and the statistics used to derive study results. Highly technical aspects of these areas can be included in appendices as opposed to the main body of the report. The contractor shall include in the report a non-technical, stand-alone executive summary of the findings.

The contractor must produce a report that is acceptable for submission to IES external scientific peer review and that will clear this review. This generally takes a minimum of four major drafts, the required timeline for which is presented below. Contractor non-responsiveness to the report guidelines and ED comments and technical direction shall necessitate additional drafts. More information about the peer review procedures can be found on the IES website at: http://ies.ed.gov/director/pdf/SRO_reports_peerreview.pdf.

The contractor shall submit the draft report within 10 weeks after the TWG meeting (specified under Task 2 as being held by no later than 75 weeks after the effective date of the contract). The COR will review and provide comments within three weeks.

The contractor shall incorporate comments and submit a revised report to the COR within 3 weeks after receipt of COR comments. The COR will review the revised report within two weeks. ED will expect the revised draft to be fully responsive to COR comments on the draft report and, thus, acceptable for peer review submission (anticipated by 86 weeks after the effective date of the contract) and if it is not, the contractor shall submit revisions until the comments are adequately addressed so that the COR can submit the report for peer review. Peer review comments are generally received within 5 to 6 weeks of report submission. From peer review submission to report clearance generally takes about 5 to 6 months and at least two revisions.

After receipt of initial comments from the peer review, the contractor shall make appropriate revisions to the report and produce a response memo detailing how…