SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Comprehensive Program Application 1840-0514

Fund for the Improvement of Postsecondary Education

**     **

**A. Justification**

1\. Explain the circumstances that make the collection of information
necessary. Identify any legal or administrative requirements that
necessitate the collection. Attach a copy of the appropriate section of
each statute and regulation mandating or authorizing the collection of
information.

Consistent with the provisions of P.L 105-244 (Title VII, Part B of the
Higher Education Act as amended in 1998), the Fund for the Improvement
of Postsecondary Education (FIPSE) works to improve postsecondary
education through grants to institutions of higher education and other
public and private nonprofit organizations. Such grants are awarded on
the basis of competitively reviewed applications submitted to FIPSE
under its Comprehensive Program grants competition. Continued funding
for each grant is based on the availability of funds and substantial
progress in achieving project objectives. The Department of Education
(ED) is requesting approval of the forms and information used to solicit
applications for new grants under this program beginning FY 2006.

The application used for the FY 2004 competition (ED 40-514, OMB
1840-0514) expires 7/31/2006. (There were no funds for new grant awards
in FY 2005.) Regulations governing this program are contained in the
Education Department General Administrative Regulations (34 CFR Parts
74, 77, 79, 80, 81, 82, and 85).

Attached is the section of the statute (P.L. 105-244) authorizing the
requested collection.

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

The attached application information, instructions, and forms are
necessary to standardize applications and to ensure that applicants
provide the information required to process and review them effectively.
The attached forms request the same general and budgetary information
requested in the past.

These are the revisions to The Comprehensive Program application since
its last clearance:

1.  Electronic submission of applications through the Department of
    Education's e-Application system has been made mandatory. This was
    voluntary when the application was last cleared. The Department of
    Education's approved language for mandatory submission of
    e-Applications has replaced that for voluntary submission.

2.  The review for the competition has been changed from a two-stage
    process with a 5-page preliminary application and invitations for a
    25-page final application to a single-stage review process with a
    20-page application. All references to "preliminary" and "final"
    proposals have been removed. This change in the review process is
    being made due to (a) time constraints on the review process
    associated with appropriation delays and resulting inadequate time
    for two separate e-Reader review periods required under a two-stage
    process and (b) the competition's anticipated transition in FY 2007
    to Grants.gov, which does not easily accommodate a two-stage review
    process.

3.  The invitational priorities for the competition have been changed to
    address the following areas of particular national need:

-   Access to quality, affordable higher education.

-   Curricular alignment from high school through college.

-   Teacher preparation in science and mathematics.

> The priorities as presented in the application package have been
> reviewed and approved by the Assistant Secretary for Postsecondary
> Education. They are consistent with the competition's previous
> invitational priorities, although more focused.

4.  The criteria for evaluation of proposals, chosen from those provided
    in 34 CFR 75, have been reduced from seven to five. The two criteria
    removed were duplicative and/or have shown marginal discriminating
    value in the review process. The two were:

-   #5 -- The quality of the management plan. (This was not sufficiently
    different from criterion #3 -- The quality of the project's design.)

-   #6 -- The quality of project personnel.

> The removal of these criteria is intended to reduce burden for
> applicants and reviewers.

5.  The special Budget Summary Form for the Comprehensive Program
    currently in use has been replaced by the Department of Education's
    Budget Information Form (ED 524).

Reviewers (external field readers and FIPSE program staff) use the
information received from this collection to evaluate grant
applications. Over the past five years, 50 to 60 grant awards have been
made annually; the same is expected in FY 2006. When the Comprehensive
Program was conducted as a two-stage competition, about 1,500
preliminary proposals were received annually, and 150 to 200 full
proposals were invited for review at the final stage. FIPSE has no
historical data on which to estimate the number of applications it will
receive in a single-stage competition. FIPSE is preparing for receipt of
750 to 1,000 applications in FY 2006. Burden calculations for Items 12
and 13 below are based on an estimated 875 applications.

3\. Describe whether, and to what extent, the collection of information
involves the use of automated, electronic, mechanical, or other
technological collection techniques or forms of information technology,
e.g. permitting electronic submission of responses, and the basis for
the decision of adopting this means of collection. Also describe any
consideration of using information technology to reduce burden.

As noted in the response to Item 2 above, both the collection and review
of applications will be done electronically. Applications must be
submitted through the Department of Education's e-Application system in
FY 2006. Grants.gov will be used in FY 2007 forward. External field
readers will review applications using the Department's e-Reader system.
FIPSE has adopted these procedures to support the Department's
electronic initiatives and to reduce burden to applicants.

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

FIPSE has made every effort to ensure there is no duplication of data
acquisition. The elimination of two evaluation criteria is designed to
address duplication of effort by applicants and reviewers that has been
identified in recent review cycles.

In the required discussion of the project design, applicants nearly
always include the [management plan]{.underline} (who, what, when, and
at what cost), since instructions for the project design criterion
specifically ask for this information. Removing the management plan
criterion will eliminate duplication.

The current criterion concerning [project personnel]{.underline} has
been eliminated since this too can be evaluated under project design.
Applicants will still be required to provide information on the
backgrounds of key project personnel, their responsibilities, and their
timelines for completing project tasks.

5\. If the collection of information impacts small businesses or other
small entities (Item 5 of OMB Form 83-I), describe any methods used to
minimize burden.

The collection of information does not impact small businesses or other
small entities unless they should choose voluntarily to participate in a
partnership that applies for funds.

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

The application process will occur once each year to enable applicants
to compete for federal funds that are appropriated annually by Congress.
This once-per-year application is the lowest frequency possible to award
annual appropriations.

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

-   Requiring respondents to report information to the agency more often
    than quarterly;

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

-   Requiring respondents to submit more than an original and two copies
    of any document;

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

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

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

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

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

No special circumstances apply.

8.  If applicable, provide a copy and identify the date and page number
    of publication in the Federal Register of the agency's notice,
    required by 5 CFR 1320.8(d), soliciting comments on the information
    collection prior to submission to OMB. Summarize public comments
    received in response to that notice and describe actions taken by
    the agency in response to these comments. Specifically address
    comments received on cost and hour burden.

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

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

This application form has been used by FIPSE for nearly 25 years with
gradual refinements and simplifications in layout based on comments by
applicants, external reviewers of applications, currently funded project
directors, national associations, FIPSE's National Board, and other
leaders in postsecondary education. There will be an opportunity for
comment in response to the Regulatory Information Management Service's
(RIMS) public comment notice tentatively scheduled to be released
2/27/2006. Any comments received and their analysis will be forwarded to
OMB.

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

No payments or gifts are provided to respondents.

10\. Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.

No assurance of confidentiality is provided to respondents except as
provided by the Privacy Act and the Department of Education's policies
governing the review of discretionary grant applications.

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

There are no questions of a sensitive nature.

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

-   Indicate the number of respondents, frequency of response, annual
    hour burden, and an explanation of how the burden was estimated.
    Unless directed to do so, agencies should not conduct special
    surveys to obtain information on which to base hour burden
    estimates. Consultation with a sample (fewer than 10) of potential
    respondents is desirable. If the hour burden on respondents is
    expected to vary widely because of differences in activity, size, or
    complexity, show the range of estimated hour burden, and explain the
    reasons for the variance. Generally, estimates should not include
    burden hours for customary and usual business practices.

-   If this request for approval covers more than one form, provide
    separate hour burden estimates for each form and aggregate the hour
    burdens in item 13 of OMB Form 83-I.

-   Provide estimates of annualized cost to respondents of the hour
    burdens for collections of information, identifying and using
    appropriate wage rate categories. The cost of contracting out or
    paying outside parties for information collection activities should
    not be included here. Instead, this cost should not be included in
    Item 14.

[Number of respondents]{.underline}: 875

[Frequency of response]{.underline}: Once a year

[Annual hour burden]{.underline}: 25 hours per application

875 applications × 25 hours = 21,875 hours

NOTE: The annual hour burden for preparation of a 20-page application
with required appendices (25 hours) was estimated based on oral accounts
of past applicants' efforts in preparing a 25-page final proposal (20
hours). Five hours were added to account for two specific program
changes: (a) elimination of the proposal development guidance provided
by FIPSE staff in the past to each preliminary applicant invited to the
final stage of the competition and (b) the time needed by applicants to
learn and to use e-Application and Grants.gov.

The typical respondent (preparer of the Comprehensive Program
application) is an associate professor at a higher education
institution. The annual salary survey conducted by the American
Association of University Professors (AAUP) reports the average 9-month
salary for an associate professor in 2004-2005 to have been \$65,113 or
approximately \$45/hour. Based on FIPSE's projected receipt of 875
applications requiring 25 hours of effort each, the estimated cost to
respondents is \$984,375.

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

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

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

-   Generally, estimates should not include purchases of equipment or
    services, or portions thereof, made: (1) prior to October 1,
    1995, (2) to achieve regulatory compliance with requirements not
    associated with the information collection, (3) for reasons other
    than to provide information or keep records for the government,
    or (4) as part of customary and usual business or private practices.

There are no start-up costs for respondents. Estimated total annual cost
burden to respondents:

> Document preparation (e.g., ink, printing, and photocopying for
> proofreading) \$4/application × 875 applications = \$3,500

Total Annualized Capital/Startup Cost : \$ 0  

Total Annual Costs (O&M) :       \$ 3,500

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Total Annualized Costs Requested : \$ 3,500

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

+--------------------------------------------------+-------------------+
| Review by FIPSE program staff                    | \$ 28,707         |
|                                                  |                   |
| (700 hours × \$41.01/hr.)                        |                   |
+--------------------------------------------------+-------------------+
| Secretarial support                              | 11,065            |
|                                                  |                   |
| (500 hours × \$22.13/hr.)                        |                   |
+--------------------------------------------------+-------------------+
| Review of 875 applications by field readers      | 146,000           |
|                                                  |                   |
| (146 readers × \$1,000)                          |                   |
+--------------------------------------------------+-------------------+
| Postage                                          | 0                 |
+--------------------------------------------------+-------------------+
| Photocopies for file and staff review            | 7,000             |
|                                                  |                   |
| (3500 applications × \$3)                        |                   |
+--------------------------------------------------+-------------------+
| TOTAL                                            | \$ 192,772        |
+--------------------------------------------------+-------------------+

15\. Explain the reasons for any program changes or adjustments reported
in Items 13 or 14 of the OMB Form 83-I.

As noted in Items 2 and 12 above, The Comprehensive Program will move
away from its long-standing two-stage competition. The transition to a
single-stage competition is the "program change" that accounts for the
projected increase in burden to applicants.

Traditionally FIPSE received 1,500 and 2,000 five-page preliminary
applications, which were used to screen applicants invited to submit
25-page applications at the final stage of the competition. In general
10 to 15 percent of the preliminary-stage applicants were invited to the
competition's final stage. We plan to transition to a single-stage
competition in FY 2006 because our timeline and current staffing levels
will not accommodate a two-stage competition. This year, for example, we
do not have time to conduct two e-Reader orientation/review periods (3
to 4 weeks each). In addition, despite the efficiency of the two-stage
review process, it does not appear that Grants.gov will accommodate it.

The single-stage application submitted to the competition will have a
20-page limit with required elements in the appendix (a chart on the
project evaluation design, key personnel summaries, and GEPA
information, plus letters of support as appropriate.) Our cost and
burden projections are based on 875 applicants submitting the 20-page
proposal, but we have no historical basis on which to estimate the
expected number of applications.

The additional burden to respondents is 2,375 hours based on the
increased number of applicants expected to submit what was previously
referred to as a "final" application.

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

No data or results of this information collection are published.

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

We will display the expiration date for OMB approval of the collection.

18\. Explain each exception to the certification statement identified in
Item 20, "Certification for Paperwork Reduction Act Submissions," of OMB
Form 83-I.

No exceptions are requested.

**B. Collection of Information Employing Statistical Methods**

The agency should be prepared to justify its decision not to use
statistical methods in any case where such methods might reduce burden
or improve accuracy of results. When Item 17 on Form 83-I is checked
"Yes," the following documentation should be included in the Supporting
Statement to the extent that it applies to the methods proposed:

FIPSE does not employ sampling or associated statistical methods in its
collection of grant applications.

1.  Describe the potential respondent universe (including a numerical
    estimate) and any sampling or other respondent selection method to
    be used. Data on the number of entities (e.g., establishments, state
    and local government units, households, or persons) in the universe
    covered by the collection and in the corresponding sample are to be
    provided in tabular form for the universe as a whole and for each of
    the strata in the proposed sample. Indicate expected response rates
    for the proposed sample. Indicate expected response rates for the
    collection as a whole. If the collection had been conducted
    previously, include the actual response rate achieved during the
    last collection.

2.  Describe the procedures for the collection of information,
    including:

-   Statistical methodology for stratification and sample selection.

-   Estimation procedure.

-   Degree of accuracy needed for the purpose described in the
    justification.

-   Unusual problems requiring specialized sampling procedures, and

-   Any use of periodic (less frequent than annual) data collection
    cycles to reduce burden.

1.  Describe methods to maximize response and to deal with issues of
    non-response. The accuracy and reliability of information collected
    must be shown to be adequate for intended uses. For collections
    based on sampling, a special justification must be provided for any
    collection that will not yield "reliable" data that can be
    generalized to the universe studied.

2.  Describe any tests of procedures or methods to be undertaken.
    Testing is encouraged as an effective means of refining collections
    of information to minimize burden and improve utility. Tests must be
    approved if they call for answers to identical questions from 10 or
    more respondents. A proposed test or set of tests may be submitted
    for approval separately or in combination with the main collection
    of information.

3.  Provide the name and telephone number of individuals consulted on
    statistical aspects of the design and the name of the agency unit,
    contractor(s), grantee(s), or other persons who will actually
    collect and/or analyze the information for the agency.

February 2006