Supporting Statement for Paperwork Reduction Act Submission

State and LEA Record Keeping and Reporting Requirements under Part B of
the IDEA

# A. Justification

Q1. 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.

A1. OMB Information Collection 1820-0600 has been revised and renamed to
reflect the provisions in the Act and the Part B regulations requiring
States and/or local educational agencies (LEAs) to collect and maintain
information or data and, in some cases, report information or data to
other public agencies or to the public. However, such information or
data are not reported to the Secretary. The following table describes
the information under Part B of the Individuals with Disabilities
Education Act (IDEA) to be collected or maintained and the legal
requirement for each collection. The required collections listed were
included in the NPRM as separate collections and have been collapsed
into this revised 1820-0600.

+-------------------------------+------------------+------------------+
| **Required Collection**       | **Statutory      | **Regulatory     |
|                               | Authority**      | Authority**      |
+===============================+==================+==================+
| *LEA consultation with        | 20 U.S.C.        | §§300.134 and    |
| private school                | 141              | 300.135          |
| representatives*. Each LEA    | 2(a)(10)(A)(iii) |                  |
| must provide to private       | and (iv)         |                  |
| school officials a written    |                  |                  |
| explanation of the reasons    |                  |                  |
| why the LEA chose not to      |                  |                  |
| provide services directly or  |                  |                  |
| through a contract and the    |                  |                  |
| LEA must obtain a written     |                  |                  |
| affirmation signed by the     |                  |                  |
| representatives of            |                  |                  |
| participating private schools |                  |                  |
| that timely and meaningful    |                  |                  |
| consultation has occurred and |                  |                  |
| forward the documentation of  |                  |                  |
| the consultation process to   |                  |                  |
| the State educational agency  |                  |                  |
| (SEA)                         |                  |                  |
+-------------------------------+------------------+------------------+
| *Private school complaint of  | 20 U.S.C.        | §300.136         |
| noncompliance with            | 1                |                  |
| consultation requirements*. A | 412(a)(10)(A)(v) |                  |
| private school official may   |                  |                  |
| submit a complaint to the SEA |                  |                  |
| that the LEA did not engage   |                  |                  |
| in consultation that was      |                  |                  |
| meaningful and timely, or did |                  |                  |
| not give due consideration of |                  |                  |
| the private school official.  |                  |                  |
+-------------------------------+------------------+------------------+
| *Number of children with      | 20 U.S.C.        | §300.132         |
| disabilities enrolled in      | 1412             |                  |
| private schools by their      | (a)(10)(A)(i)(V) |                  |
| parents*. Each LEA must       |                  |                  |
| maintain in its records and   |                  |                  |
| annually provide to the SEA   |                  |                  |
| the number of children        |                  |                  |
| enrolled in private schools   |                  |                  |
| by their parents that are     |                  |                  |
| evaluated by the LEA to       |                  |                  |
| determine whether they are    |                  |                  |
| children with disabilities    |                  |                  |
| under IDEA, the number of     |                  |                  |
| children determined to be     |                  |                  |
| children with disabilities    |                  |                  |
| under IDEA, and the number of |                  |                  |
| children receiving special    |                  |                  |
| education and related         |                  |                  |
| services in accordance with   |                  |                  |
| 20 U.S.C. 1412(a)(10)(A).     |                  |                  |
+-------------------------------+------------------+------------------+
| *State plan for high cost     | 20 U.S.C.        | §300.704         |
| fund*. Any State educational  | 1                |                  |
| agency (SEA), not later than  | 411(e)(3)(C)(ii) |                  |
| 90 days after the State       |                  |                  |
| chooses to reserves funds     |                  |                  |
| under 20 U.S.C.               |                  |                  |
| 1411(e)(3)(C)(ii) shall       |                  |                  |
| annually review, and amend as |                  |                  |
| necessary, a State plan for   |                  |                  |
| the high cost fund.           |                  |                  |
+-------------------------------+------------------+------------------+
| *Free and low-cost legal      | 20 U.S.C.        | §300.507         |
| services.* Each public agency | 1415(b)(6)       |                  |
| shall inform the parent of    |                  |                  |
| any free or low-cost legal    |                  |                  |
| and other relevant services   |                  |                  |
| available in the area if the  |                  |                  |
| parent requests the           |                  |                  |
| information or the parent or  |                  |                  |
| agency requests a hearing     |                  |                  |
| under this part.              |                  |                  |
+-------------------------------+------------------+------------------+
| *Early intervening services   | 20 U.S.C.        | §300.226         |
| annual report.* Each LEA that | 1413(f)(4)       |                  |
| develops and maintains        |                  |                  |
| coordinated, early            |                  |                  |
| intervening services is       |                  |                  |
| required to annually report   |                  |                  |
| to the SEA on the number of   |                  |                  |
| children serviced through     |                  |                  |
| early intervening services    |                  |                  |
| and the number of children    |                  |                  |
| who subsequently receive      |                  |                  |
| special education and related |                  |                  |
| services under Part B of the  |                  |                  |
| Act during the preceding two  |                  |                  |
| year period.                  |                  |                  |
+-------------------------------+------------------+------------------+
| *List of hearing officers and | 20               | §300.506 and     |
| mediators*. Each State        | U.S              | 300.511          |
| receiving funds under Part B  | .C.1415(e)(2)(C) |                  |
| must maintain a list of       |                  |                  |
| individuals who are qualified |                  |                  |
| mediators and knowledgeable   |                  |                  |
| in laws and regulations       |                  |                  |
| relating to the provision of  |                  |                  |
| special education and related |                  |                  |
| services. Each public agency  |                  |                  |
| must maintain a list of       |                  |                  |
| individuals who serve as      |                  |                  |
| hearing officers, along with  |                  |                  |
| the qualifications of each of |                  |                  |
| these individuals. (This      |                  |                  |
| information was included in   |                  |                  |
| previous OMB Collection       |                  |                  |
| 1820-0509)                    |                  |                  |
+-------------------------------+------------------+------------------+
| *State complaint procedures.* |                  | §                |
| Each SEA participating in the |                  | §300.151-300.153 |
| program funded under Part B   |                  |                  |
| must adopt written procedures |                  |                  |
| for receiving and resolving   |                  |                  |
| complaints alleging that the  |                  |                  |
| State (grantee) or a sub      |                  |                  |
| grantee is violating a Part B |                  |                  |
| statutory or regulatory       |                  |                  |
| requirement. (This            |                  |                  |
| information was included in   |                  |                  |
| former OMB Collection 0599)   |                  |                  |
+-------------------------------+------------------+------------------+
| *LEA application under Part   | 20 U.S.C.        | §§               |
| B, and report of early        | 1413(f)          | 300.201-300.213, |
| intervening services*. LEAs   |                  | §300.224,        |
| and eligible state agencies   | 20 U.S.C.        | §300.226, and    |
| must submit a plan to the SEA | 1415(d)          | §300.504.        |
| that provides assurances that |                  |                  |
| the LEA meets specified       |                  |                  |
| requirements for assistance   |                  |                  |
| under Part B and the          |                  |                  |
| regulations and, if           |                  |                  |
| applicable, annually report   |                  |                  |
| to the SEA on the number of   |                  |                  |
| students served under 20      |                  |                  |
| U.S.C. 1413(f) and the number |                  |                  |
| of students served under 20   |                  |                  |
| U.S.C.20 1413(f) who          |                  |                  |
| subsequently receive special  |                  |                  |
| education and related         |                  |                  |
| services in Part B during the |                  |                  |
| preceding 2-year period, if   |                  |                  |
| the LEA develops and          |                  |                  |
| maintains coordinated, early  |                  |                  |
| intervening services under 20 |                  |                  |
| U.S.C. 1413(f). (Note: This   |                  |                  |
| incorporates information from |                  |                  |
| the information collection in |                  |                  |
| the NPRM titled *Early        |                  |                  |
| Intervening Services Annual   |                  |                  |
| Report*). Included in this    |                  |                  |
| collection is the requirement |                  |                  |
| that a parent of a child with |                  |                  |
| a disability must be provided |                  |                  |
| a copy of the procedural      |                  |                  |
| safeguard notice only one     |                  |                  |
| time a year (except one shall |                  |                  |
| be provided upon referral or  |                  |                  |
| request for an evaluation,    |                  |                  |
| filing a due process          |                  |                  |
| complaint, or upon request).  |                  |                  |
+-------------------------------+------------------+------------------+

Q2. 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.

A2. The information is used by SEAs and LEAs and is not collected by the
U.S. Department of Education.

Q3. 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.

A3. Local educational agencies (LEAs) and State educational agencies
(SEAs) are encouraged to use computer technology when feasible and cost
effective. We estimate that approximately 70% of the information
gathered through this collection will be collected electronically. There
are no technical or legal obstacles to reducing the burden to LEAs and
SEAs.

Q4. 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.

A4. Duplication of this collection does not exist.

Q5. 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.

A5. This collection does not involve small business or entities.

Q6. 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.

A6. If the information collection under these final regulations is not
conducted, SEAs, LEAs, and schools will not have information necessary
to carry out the requirements of the law.

Q7. 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 that 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.

A7. This section is not applicable. No data or information is submitted
to the U.S. Department of Education. Information collection methods and
timing is at the discretion of the States.

Q8. If applicable, provide a copy and identify the date and page number
of 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.

A8. Comments were solicited through the Notice of Proposed Rule Making
(NPRM) implementing the IDEA (Federal Register, Vol. 70, No. 118, June
21, 2005). All public comments are addressed in the final regulations.
No substantive comments were received regarding this collection;
however, a few commenters stated that the estimated burden hours should
be reviewed as, in some instances, they are too low. As a result of
comments received we reviewed the estimated burden hours and adjustments
were made.

Q9. Explain any decision to provide any payment or gift to respondents,
other than renumeration of contractors or grantees.

A9. This item is not applicable. There is no assurance. There was no
decision to provide any payment or gift to respondents.

Q10. Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulations, or agency
policy.

A10. This section is not applicable. There is no assurance of
confidentiality provided to respondents.

Q11. 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. This 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.

A11. There are no questions of a sensitive nature.

Q12. 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 be included in Item
    14.

A12.

+-----------------------+---------------+-------+-----------+--------+
| Collection            | Respondents,  | Total | Cost      | Total  |
|                       | Frequency,    | A     | Burden    | Cost   |
|                       | Burden        | nnual | Estimate  |        |
|                       |               | B     |           |        |
|                       |               | urden |           |        |
|                       |               | Hours |           |        |
+=======================+===============+=======+===========+========+
| *LEA consultation     | (2,849 LEAs x | 3     | 35,556 x  | \$8    |
| with private school   | 12 hrs) + (57 | 5,556 | \$25      | 88,900 |
| representatives.* It  | SEA x 24 hrs) |       |           |        |
| is estimated that     |               |       |           |        |
| approximately 2,849   |               |       |           |        |
| LEA recordkeepers     |               |       |           |        |
| will be required to   |               |       |           |        |
| provide written       |               |       |           |        |
| explanations to       |               |       |           |        |
| private school        |               |       |           |        |
| officials and obtain  |               |       |           |        |
| a written affirmation |               |       |           |        |
| signed by the         |               |       |           |        |
| representatives of    |               |       |           |        |
| participating private |               |       |           |        |
| schools and forward   |               |       |           |        |
| the documentation of  |               |       |           |        |
| the consultation      |               |       |           |        |
| process to the State  |               |       |           |        |
| educational agency    |               |       |           |        |
| (SEA). It is          |               |       |           |        |
| estimated that it     |               |       |           |        |
| will take, on         |               |       |           |        |
| average, each LEA     |               |       |           |        |
| approximately 12      |               |       |           |        |
| hours per year to     |               |       |           |        |
| obtain a written      |               |       |           |        |
| affirmation and       |               |       |           |        |
| forward documentation |               |       |           |        |
| to the SEA. There are |               |       |           |        |
| 57 SEA recordkeepers  |               |       |           |        |
| who receive the       |               |       |           |        |
| documentation from    |               |       |           |        |
| each LEA. It is       |               |       |           |        |
| estimated that, on    |               |       |           |        |
| the average for all   |               |       |           |        |
| SEAs, it takes        |               |       |           |        |
| recordkeepers 24      |               |       |           |        |
| hours per year to     |               |       |           |        |
| maintain the records. |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *Private school       | Private       | 5,320 | 5,320 x   | \$1    |
| complaint of          | school        |       | \$25      | 33,000 |
| noncompliance with    | burden: (200  |       |           |        |
| consultation          | private       |       |           |        |
| process.*             | school        |       |           |        |
| Approximately 200     | respondents x |       |           |        |
| private school        | 2hrs) + (30   |       |           |        |
| officials are         | private       |       |           |        |
| estimated to annually | school        |       |           |        |
| choose to file a      | respondents x |       |           |        |
| complaint with SEAs   | 2hrs) = 460   |       |           |        |
| that LEAs did not     |               |       |           |        |
| engage in             | SEA burden:   |       |           |        |
| consultation that was | (40 SEA       |       |           |        |
| meaningful and        | respondents x |       |           |        |
| timely, or did not    | 5 complaints  |       |           |        |
| give due              | x 20 hrs) +   |       |           |        |
| consideration to the  | (40 SEA       |       |           |        |
| views of the private  | respondents x |       |           |        |
| school officials and  | 2hrs) = 4,080 |       |           |        |
| 30 private school     |               |       |           |        |
| officials will choose | LEA burden:   |       |           |        |
| to file a complaint   | 200 LEA       |       |           |        |
| with the Secretary.   | respondents x |       |           |        |
| It is estimated that  | 4hrs = 800    |       |           |        |
| on average each of 40 |               |       |           |        |
| SEAs will render a    |               |       |           |        |
| decision for 5        |               |       |           |        |
| complaints and will   |               |       |           |        |
| be required to submit |               |       |           |        |
| documentation to the  |               |       |           |        |
| Secretary for 1       |               |       |           |        |
| complaint.            |               |       |           |        |
| Approximately 200     |               |       |           |        |
| LEAs across 40 States |               |       |           |        |
| will be required to   |               |       |           |        |
| forward documentation |               |       |           |        |
| to SEAs regarding     |               |       |           |        |
| complaints.           |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *Number of children   | LEA burden:   | 14    | 143,430 x | \$3,5  |
| with disabilities     | 14,229 LEA    | 3,430 | \$25      | 85,750 |
| enrolled in private   | respondents x |       |           |        |
| schools by their      | 10 (hrs) =    |       |           |        |
| parents.* There are   | 142,290       |       |           |        |
| 14,229 LEA            |               |       |           |        |
| respondents who are   | SEA burden:   |       |           |        |
| required to maintain  | 57 SEA        |       |           |        |
| a record of the       | respondents x |       |           |        |
| number of children    | 20 (hrs) =    |       |           |        |
| evaluated, the number | 1,140         |       |           |        |
| of children           |               |       |           |        |
| determined to be      |               |       |           |        |
| children with         |               |       |           |        |
| disabilities, and the |               |       |           |        |
| number of children    |               |       |           |        |
| served under 20       |               |       |           |        |
| U.S.C.                |               |       |           |        |
| 1412(a)(10)(A). There |               |       |           |        |
| are 57 SEA            |               |       |           |        |
| respondents who       |               |       |           |        |
| receive the records   |               |       |           |        |
| from each LEA.        |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *State plan for high  | 40 SEA        | 1,600 | 1,600 x   | \$     |
| cost fund*. It is     | respondents x |       | \$25      | 40,000 |
| anticipated that      | 40 (hrs)      |       |           |        |
| approximately 40      |               |       |           |        |
| States will choose to |               |       |           |        |
| maintain a high cost  |               |       |           |        |
| fund necessitating a  |               |       |           |        |
| State plan for the    |               |       |           |        |
| high cost fund. It is |               |       |           |        |
| estimated that it     |               |       |           |        |
| will take each State  |               |       |           |        |
| an average of 40      |               |       |           |        |
| hours to annually     |               |       |           |        |
| review and amend 40   |               |       |           |        |
| State plans which     |               |       |           |        |
| equals an estimated   |               |       |           |        |
| total of 1,600 total  |               |       |           |        |
| burden hours.         |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *Free and low-cost    | 13,000 LEA    | 6,500 | 6,500 x   | \$1    |
| legal services*.      | respondents x |       | \$25      | 62,500 |
| There are             | .5 (hrs.)     |       |           |        |
| approximately 13,000  |               |       |           |        |
| due process hearings  |               |       |           |        |
| requested annually    |               |       |           |        |
| through LEAs. The     |               |       |           |        |
| data burden is        |               |       |           |        |
| expected to require   |               |       |           |        |
| an average of 30      |               |       |           |        |
| minutes per hearing   |               |       |           |        |
| request to inform     |               |       |           |        |
| parents of the        |               |       |           |        |
| availability of       |               |       |           |        |
| low-cost legal        |               |       |           |        |
| services.             |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *Early intervening    | 5,691 LEA     | 12    | 125,202 x | \$3,1  |
| services annual       | respondents x | 5,202 | \$25      | 30,050 |
| report.* There are an | 22 (hrs)      |       |           |        |
| estimated 5,691 LEA   |               |       |           |        |
| that will be required |               |       |           |        |
| to collect this data  |               |       |           |        |
| and it is estimated   |               |       |           |        |
| that it will take     |               |       |           |        |
| each LEA 22 hours to  |               |       |           |        |
| gather the data       |               |       |           |        |
| needed and prepare    |               |       |           |        |
| information to report |               |       |           |        |
| to the SEA.           |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *List of hearing      | 14,286        | 4     | 42,858 x  | \$1,0  |
| officers and          | SEA/LEA       | 2,858 | \$25      | 71,450 |
| mediators* (previous  | respondents x |       |           |        |
| OMB 1820-0509)*.*     | 3 (hrs)       |       |           |        |
| There are 57 State    |               |       |           |        |
| level record keepers  |               |       |           |        |
| who must maintain a   |               |       |           |        |
| list of mediators and |               |       |           |        |
| approximately 14,229  |               |       |           |        |
| public agencies. It   |               |       |           |        |
| is estimated to take  |               |       |           |        |
| approximately three   |               |       |           |        |
| hours annually for    |               |       |           |        |
| record keepers to     |               |       |           |        |
| update and maintain   |               |       |           |        |
| the lists.            |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *State complaint      | 57 SEA        | 4     | 41,040 x  | \$1,0  |
| procedures* (previous | respondents x | 1,040 | \$25      | 26,000 |
| OMB 1820-0599). Each  | 30 = 1,710 x  |       |           |        |
| of 57 SEAs process,   | 24 hrs.       |       |           |        |
| on average, 30        |               |       |           |        |
| complaints annually.  |               |       |           |        |
| It takes an average   |               |       |           |        |
| of about 24 hours for |               |       |           |        |
| a State educational   |               |       |           |        |
| agency to issue a     |               |       |           |        |
| written decision to a |               |       |           |        |
| complaint.            |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *LEA application      | 14,229 LEA    | 2     | 28,458 x  | \$7    |
| under Part B*         | respondents x | 8,458 | \$25      | 11,450 |
| (previous OMB         | 2 (hrs)       |       |           |        |
| 1820-0600). It is     |               |       |           |        |
| estimated that each   |               |       |           |        |
| of 14,229 respondents |               |       |           |        |
| will expend a total   |               |       |           |        |
| of 2 hours annually   |               |       |           |        |
| processing            |               |       |           |        |
| modifications to an   |               |       |           |        |
| LEA plan for Part B   |               |       |           |        |
| funds and reporting.  |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| *Procedural Safeguard | 14,229 LEA    | 4     | 42,687 x  | \$1,0  |
| Notice.* It is        | respondents x | 2,687 | \$25      | 67,175 |
| estimated that each   | 3 (hrs)       |       |           |        |
| of 14,229 respondents |               |       |           |        |
| will expend a total   |               |       |           |        |
| of 3 hours annually   |               |       |           |        |
| generating and        |               |       |           |        |
| providing procedural  |               |       |           |        |
| safeguard notices to  |               |       |           |        |
| parents of children   |               |       |           |        |
| with disabilities.    |               |       |           |        |
+-----------------------+---------------+-------+-----------+--------+
| **TOTAL BURDEN**      | **79,194**    | *     |           | **     |
|                       |               | *472, |           | 11,816 |
|                       |               | 651** |           | ,275** |
+-----------------------+---------------+-------+-----------+--------+

Q13. 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 rates(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.

A13. It is not likely that a public agency will incur costs other than
those described in item 12 above.

> Q14. 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.

A14. There is no cost to the Federal government.

Q15. Explain the reasons for any program changes or adjustments reported
in Items 13 or 14 of the OMB Form 83-I.

A15. There is an increase in the number of respondents from 29,482 to
79,194 and in the number of burden hours from current OMB inventory of
85,017 to 472,651. This increase in the number of respondents is a
result of combining the collections in the NPRM (see A1) into this
collection. The increase in burden hours is the result of three factors:
(1) The combining of the collections in the NPRM into this new version
of 1820-0600 (previous OMB 1820-0600 included burden for the LEA
application under Part B and the requirement regarding procedural
safeguard notices), (2) an adjustment in the burden for the *list of
hearing officers and mediators* (previous OMB 1820-0509), *LEA
application under Part B* (previous OMB 1820-0600), and *State complaint
procedures* (previous OMB 1820-0599) as a result of refiguring burden,
and (3) a program change due to statutory requirements. With the
adjustments in figuring the burden for these collections, the net
increase adjustment is 27,339 hours. The remaining burden of 360,295
hours is a program change as a result of new statutory requirements.

Q16. 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.

A16. No complex analytical techniques will be used.

Q17. If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that display
would be inappropriate.

A17. This section is not applicable, since this is a recordkeeping
requirement. There is no request to not display the expiration data for
OMB approval.

Q18. Explain each exception to the certification statement identified in
Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB
Form 83-I.

A18. This section is not applicable. There are no exceptions to item 19
of the "Certification for Paperwork Reduction Act Submissions."

B. [Collections of Information Employing Statistical
Methods]{.underline}

This collection does not employ statistical methods.