**U.S. Department of Education**

College Assistance Migrant Program (CAMP)

*Office of Management and Budget*

*Clearance Package Supporting Statement*

*And Data Collection Instrument*

August 7, 2008

**TABLE OF CONTENTS**

A. JUSTIFICATION

A.1 Circumstances Making The Collection of Information Necessary 1

A.2 Purposes and Uses of the Data 1

A.3 Use Of Technology to Reduce Burden 2

A.4 Efforts To Identify Duplication 2

A.5 Methods to Minimize Burden on Small Entities 2

A.6 Consequences of Not Collecting Data 2

A.7 Special Circumstances 2

A.8 Federal Register Comments and Persons Consulted Outside The Agency 2

A.9 Payments or Gifts 3

A.10 Assurances of Confidentiality 3

A.11 Justification of Sensitive Questions 3

A.12 Estimates of Hour Burden 3

A.13 Estimates of Cost Burden to Respondents 4

A.14 Estimate of Annual Cost to the Federal Government 4

A.15 Program Changes or Adjustments 4

A.16 Plans For Tabulation And Publication of Results 4

A.17 Approval To Not Display The OMB Expiration Date 4

A.18 Explanation of Exceptions 4

B. COLLECTION OF INFORMATION EMPLOYING\
STATISTICAL METHODS

> APPENDIX A: AUTHORIZING LEGISLATION
>
> APPENDIX B: GOVERNMENT PERFORMANCE AND RESULTS ACT
>
> APPENDIX C: DATA COLLECTION INSTRUMENT

**A. JUSTIFICATION**

**A1. 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
the information.**

The College Assistance Migrant Program (CAMP) office staff is collecting
information for the CAMP Annual Performance Report (APR) is being
collected in compliance with Higher Education Act of 1965, as amended,
Title IV, Sec. 418A; 20 U.S.C*.* 1070d-2 (special programs for students
whose families are engaged in migrant and seasonal farmwork) (shown in
appendix A), the Government Performance Results Act (GPRA) of 1993,
Section 4 (1115) (shown in appendix B), and the Education Department
General Administrative Regulations (EDGAR), 34 CFR 75.253. EDGAR states
that recipients of multi-year discretionary grants must submit an APR
demonstrating that substantial progress has been made towards meeting
the approved objectives of the project. In addition, EDGAR requires
discretionary grantees to report on their progress toward meeting the
performance measures established for the ED grant program.

# The CAMP office staff requests a customized APR that goes beyond the generic 524B APR to facilitate the collection of more standardized and comprehensive data to inform GPRA, to improve the overall quality of data collected, and to increase the quality of data that can be used to inform policy decisions.

**A2. Indicate how, by whom, and for what purpose the information will
be used. Except for a new collection, indicate the actual use the agency
has made of the information received from the current collection.**

The CAMP office staff will collect information via the APR submitted by
CAMP grantees in compliance with GPRA 1993 section 4, sub-section 1115.
APRs are submitted once a year and are used to monitor grantee progress.
We request a customized APR that goes beyond the generic 524B APR to
facilitate the collection of more standardized and comprehensive data to
inform GPRA, to improve the overall quality of data collected, and to
increase the quality of data that can be used for evaluation and to
inform policy decisions.

With regard to information quality, OMB (2002) identified the following
general guidelines for ensuring information quality[^1]:

1)  Soliciting input from a variety of sources and perspectives and

2)  Subjecting draft materials to a review process as well as the
    following steps to assure information objectivity and utility:

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a.  Preparing a draft of the document after consulting the necessary
    parties, including government and non-government sources, as
    appropriate;

b.  Determining/assuring accuracy and completeness of data sources;

c.  Determining the expected uses by the government and public;

d.  Determining necessary clearance points;

e.  Determining where the final decision should be made;

f.  Determining whether peer review would be appropriate and, if
    necessary, coordinating such review;

g.  Obtaining clearances; and

h.  Overcoming delays and, if necessary, presenting the matter to higher
    authority.

Further, OMB stipulated data integrity as a measure of information
quality and recommended adequate hardware, software, and operational
support to ensure data is not compromised.

As it pertains to data a) collected from grantees in response to GPRA
1993 requirements and b) made public, either in original form or as
documentation supporting other program reports, the CAMP office will
follow the recommended steps outlined above, to the extent practicable
under circumstances at the time. Further, the program and its grantees
will receive technical assistance through the ED's Data Quality
Initiative to ensure data and analyses meet high technical standards and
expectations.

**A3. Describe whether, and to what extent, the collection of
information involves the use of automated, electronic, mechanical, or
other technological collection techniques or other forms of information
technology.**

The revised APR form will be collected via an online form accessible
only to grantees. This may improve the timeliness of submission,
accuracy of data, and reduce cost or burden associated with regular mail
or email. It will also reduce the CAMP office's cost associated with
data analysis. All information collected in support of the APR will be
collected in compliance with grantee evaluation requirements.

**A4. Describe efforts to identify duplication. Show specifically why
any similar information already available cannot be used or modified for
use for the purposes described in item 2 above.**

There is no duplication of reporting on the CAMP APR. Data are reported
annually covering the specified reporting period. The information
requested on the APR from CAMP grantees is not collected or reported
elsewhere. It will replace and enhance the data currently collected by
the 524-B form.

**A5. If the collection of information involves small businesses or
other small entities, describe any methods used to minimize burden.**

The data collection does not involve small businesses or other small
entities.

**A6. Describe the consequences to the 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 APR is a requirement of funded CAMP projects, as stipulated in GPRA
1993, Section 4. Annual reporting ensures each grantee is:

-   implementing project activities as described in their grant proposal
    and funding agreement;

-   reducing waste and inefficiencies through the collection, analysis
    and use of formative information;

-   contributing to desired progress on program indicators.

Less frequent or no annual reporting risks waste, inefficiency and/or
lack of progress on desired indicators due to insufficient oversight. In
addition, the CAMP's most recent PART rating was "Results Not
Demonstrated," and ED would like to use data from the customized APR to
improve that rating.

**A7. Explain any special circumstances that require the collection to
be conducted in a manner inconsistent with OMB guidelines.**

There are no special circumstance that would require the collection to
be conducted in a manner inconsistent with OMB guidelines.

**A8. 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 comment on the information
collection prior to submission to OMB. Summarize the public comments
received in response to that notice and describe the actions taken by
the agency in response to those 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
instructions and recordkeeping, disclosure, or reporting format (if
any), and on the data elements to be recorded, disclosed, or reported.**

We will publish both the 60-day and 30-day Federal Register notices and
will provide them with this document when available.

A draft of the CAMP APR was initially mailed to all CAMP directors and
project evaluators, then, reviewed during a presentation at the National
Association of State Directors of Migrant Education (NASDME) conference
that occurred from April 20-23, 2008 in Orlando, Florida. At that time,
we received verbal and written feedback on the draft APR from almost all
CAMP projects. We revised the draft APR incorporating changes that
derived from that feedback. Then, CAMP directors and project evaluators
were given a second opportunity, on July 9^th^, 2008 at the annual
HEP-CAMP meeting in Crystal City, VA, to review and comment on the
revised, draft APR on the topics of 1) availability of data, 2) clarity
of instructions and recordkeeping, and the 3) reporting format. The
draft APR has since been revised to reflect additional changes derived
from the verbal and written feedback we received from CAMP projects at
the aforementioned HEP-CAMP meeting.

In addition, we will notify all grantees via a listserve to submit
feedback during the 60-day public comment period.

**A9. Explain any decision to provide payments or gifts to respondents,
other than remuneration of contractors or grantees.**

There are no payments or gifts to grantees in support of the data
collection.

**A10. Describe any assurance of confidentiality provided to respondents
and the basis for assurance in statute, regulation, or agency policy.**

There are no assurances of confidentiality to grantees.

**A11. 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.**

There are no questions of a sensitive nature on the APR.

**A12. Provide an estimate in hours of the burden of the collection of
information.**

We anticipate a burden of approximately 40 hours per grantee. With 38
grantees, that would be a total of about 1,520 hours. Using a cost
estimate of \$40 per hour, the cost burden per grantee would be about
\$1,600, or a total for all 38 grantees of about \$60,800.

Please note that in 2007, our office, Office of Migrant Education (OME),
received OMB approval for a similar APR for the High School Equivalency
Program (HEP), which is another program authorized under the same HEA
legislation and managed by OME. At that time, we consulted with seven
potential HEP respondents to arrive at the 40 hour [response
estimate]{.underline}. In addition, the \$40 per hour [cost
estimate]{.underline} was based on the costs for the applicants'
grant-writing staff, considering salary and fringe benefits.

**A13. Provide an estimate of the total annual cost burden to the
respondents or recordkeepers resulting from the collection of
information (do not include the cost of any hour burden shown in items
#12 and #14).**

There are no additional costs to respondents or record-keepers resulting
from the collection other than already reported in A12 and A14,
including capital or start-up costs, or operation, maintenance, or
purchase of services.

[]{.mark}

**A14. Provide estimates of annualized cost to the Federal government.**

The College Assistance Migrant Program (CAMP) office staff will conduct
the data collection for the APR. There are currently 38 CAMP grantees.
Assuming that the response for each grantee takes on average about one
hour of CAMP office staff time, and that each hour of CAMP office staff
time (including overhead) costs the federal government \$45.05 (grade
13, step 5), the annualized federal cost will be \$1,711.90

**A15. Explain the reasons for any program changes or adjustments
reported in Items 13 or 14 of the OMB 83-I.**

The annual reporting burden in item 13 of the OMB 83-I shows the 1,520
hours. In previous years, the CAMP office collected similar information
(not in standardized form) through ED's generic APR form 524B. The
reporting templates in the new customized APR will allow the CAMP office
to aggregate information for GPRA reporting and will increase data
quality.

**A16. For collections whose results will be published, outline the
plans for tabulation and publication.**

The CAMP office staff will publish findings from aggregated grantee
reports, as they pertain to the evaluation questions stated in the APR
for program and grantee use in better understanding effective service
models and strategies. The CAMP office will follow OMB recommended steps
(outlined above) to ensure information quality. Following this, the CAMP
office will engage in peer review by Education Department colleagues as
well as experts in the field for any publication of analyses resulting
from APRs.

**A17. If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons why display
would be inappropriate.**

The OMB number and expiration date will be displayed on the data
collection form.

**A18. Explain each exception to the certification statement identified
in Item 19 of the**

**OMB 83-I.**

There are no exceptions to the certification statement.

**B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS**

Data collection does not employ statistical methods.

# 

# 

#  

# Appendix A: Authorizing Legislation

**Special programs for students whose families are engaged in migrant
and seasonal farmwork**

Higher Education Act of 1965, as amended, Title IV, Sec. 418A; 20
U.S.C*.* 1070d-2

\(a\) Program authority

The Secretary shall maintain and expand existing secondary and
postsecondary high school equivalency program and college assistance
migrant program projects located at institutions of higher education or
at private nonprofit organizations working in cooperation with
institutions of higher education.

\(b\) Services provided by high school equivalency program

The services authorized by this subpart for the high school equivalency
program include---

\(1\) recruitment services to reach persons---

\(A\)

\(i\) who are 16 years of age and over; or

\(ii\) who are beyond the age of compulsory school attendance in the
State in which such persons reside and are not enrolled in school;

\(B\)

\(i\) who themselves, or whose parents, have spent a minimum of 75 days
during the past 24 months in migrant and seasonal farmwork; or

\(ii\) who are eligible to participate, or have participated within the
preceding 2 years, in programs under part C of title I of the Elementary
and Secondary Education Act of 1965 \[20 U.S.C. 6391 et seq.\] or
section 2912 of title 29; and

\(C\) who lack a high school diploma or its equivalent;

\(2\) educational services which provide instruction designed to help
students obtain a general education diploma which meets the guidelines
established by the State in which the project is located for high school
equivalency;

\(3\) supportive services which include the following:

\(A\) personal, vocational, and academic counseling;

\(B\) placement services designed to place students in a university,
college, or junior college program, or in military service or career
positions; and

\(C\) health services;

\(4\) information concerning, and assistance in obtaining, available
student financial aid;

\(5\) weekly stipends for high school equivalency program participants;

\(6\) housing for those enrolled in residential programs;

\(7\) exposure to cultural events, academic programs, and other
educational and cultural activities usually not available to migrant
youth; and

\(8\) other essential supportive services, as needed to ensure the
success of eligible students.

\(c\) Services provided by college assistance migrant program

\(1\) Services authorized by this subpart for the college assistance
migrant program include---

\(A\) outreach and recruitment services to reach persons who themselves
or whose parents have spent a minimum of 75 days during the past 24
months in migrant and seasonal farmwork or who have participated or are
eligible to participate, in programs under part C of title I of the
Elementary and Secondary Education Act of 1965 \[20 U.S.C. 6391 et
seq.\] (or such part's predecessor authority) or section 2912 of title
29, and who meet the minimum qualifications for attendance at a college
or university;

\(B\) supportive and instructional services which include:

\(i\) personal, academic, and career counseling as an ongoing part of
the program;

\(ii\) tutoring and academic skill building instruction and assistance;

\(iii\) assistance with special admissions;

\(iv\) health services; and

\(v\) other services as necessary to assist students in completing
program requirements;

\(C\) assistance in obtaining student financial aid which includes, but
is not limited to:

\(i\) stipends;

\(ii\) scholarships;

\(iii\) student travel;

\(iv\) career oriented work study;

\(v\) books and supplies;

\(vi\) tuition and fees;

\(vii\) room and board; and

\(viii\) other assistance necessary to assist students in completing
their first year of college;

\(D\) housing support for students living in institutional facilities
and commuting students;

\(E\) exposure to cultural events, academic programs, and other
activities not usually available to migrant youth; and

\(F\) other support services as necessary to ensure the success of
eligible students.

\(2\) A recipient of a grant to operate a college assistance migrant
program under this subpart shall provide followup services for migrant
students after such students have completed their first year of college,
and shall not use more than 10 percent of such grant for such followup
services. Such followup services may include---

\(A\) monitoring and reporting the academic progress of students who
participated in the project during such student's first year of college
and during such student's subsequent years in college; and

\(B\) referring such students to on- or off-campus providers of
counseling services, academic assistance, or financial aid.

\(d\) Management plan required

Each project application shall include a management plan which contains
assurances that the grant recipient will coordinate the project, to the
extent feasible, with other local, State, and Federal programs to
maximize the resources available for migrant students, and that staff
shall have a demonstrated knowledge and be sensitive to the unique
characteristics and needs of the migrant and seasonal farmworker
population, and provisions for:

\(1\) staff in-service training;

\(2\) training and technical assistance;

\(3\) staff travel;

\(4\) student travel;

\(5\) interagency coordination; and

\(6\) an evaluation plan.

\(e\) Five-year grant period; consideration of prior experience

Except under extraordinary circumstances, the Secretary shall award
grants for a 5-year period. For the purpose of making grants under this
subpart, the Secretary shall consider the prior experience of service
delivery under the particular project for which funds are sought by each
applicant. Such prior experience shall be awarded the same level of
consideration given this factor for applicants for programs in
accordance with section 1070a--11 (c)(1) of this title.

\(f\) Minimum allocations

The Secretary shall not allocate an amount less than---

\(1\) \$150,000 for each project under the high school equivalency
program, and

\(2\) \$150,000 for each project under the college assistance migrant
program.

\(g\) Data collection

The National Center for Education Statistics shall collect postsecondary
education data on migrant students.

\(h\) Authorization of appropriations

\(1\) There are authorized to be appropriated for the high school
equivalency program \$15,000,000 for fiscal year 1999 and such sums as
may be necessary for each of the 4 succeeding fiscal years.

\(2\) There are authorized to be appropriated for the college assistance
migrant program \$5,000,000 for fiscal year 1999 and such sums as may be
necessary for each of the 4 succeeding fiscal years.

# Appendix B: Government Performance Results Act of 1993

[SECTION 4. ANNUAL PERFORMANCE PLANS AND
REPORTS](http://www.whitehouse.gov/omb/mgmt-gpra/gplaw2m.html#t4).

\(a\) Budget Contents and Submission to Congress.-Section 1105(a) of
title 31, United States Code, is amended by adding at the end thereof
the following new paragraph:

\"(29) beginning with fiscal year 1999, a Federal Government performance
plan for the overall budget as provided for under section 1115.\".

\(b\) Performance Plans and Reports.-Chapter 11 of title 31, United
States Code, is amended by adding after section 1114 the following new
sections:

\"Sec. 1115. Performance plans

\(a\) In carrying out the provisions of section 1105(a)(29), the
Director of the Office of Management and Budget shall require each
agency to prepare an annual performance plan covering each program
activity set forth in the budget of such agency. Such plan shall-

\"(1) establish performance goals to define the level of performance to
be achieved by a program activity;

\"(2) express such goals in an objective, quantifiable, and measurable
form unless authorized to be in an alternative form under subsection
(b);

\"(3) briefly describe the operational processes, skills and technology,
and the human, capital, information, or other resources required to meet
the performance goals;

\"(4) establish performance indicators to be used in measuring or
assessing the relevant outputs, service levels, and outcomes of each
program activity;

\"(5) provide a basis for comparing actual program results with the
established performance goals; and

\"(6) describe the means to be used to verify and validate measured
values.

\"(b) If an agency, in consultation with the Director of the Office of
Management and Budget, determines that it is not feasible to express the
performance goals for a particular program activity in an objective,
quantifiable, and measurable form, the Director of the Office of
Management and Budget may authorize an alternative form. Such
alternative form shall-

\"(1) include separate descriptive statements of-

\"(A)(i) a minimally effective program, and

\"(ii) a successful program, or

\"(B) such alternative as authorized by the Director of the Office of
Management and Budget, with sufficient precision and in such terms that
would allow for an accurate, independent determination of whether the
program activity\'s performance meets the criteria of the description;
or

\"(2) state why it is infeasible or impractical to express a performance
goal in any form for the program activity.

\"(c) For the purpose of complying with this section, an agency may
aggregate, disaggregate, or consolidate program activities, except that
any aggregation or consolidation may not omit or minimize the
significance of any program activity constituting a major function or
operation for the agency.

\"(d) An agency may submit with its annual performance plan an appendix
covering any portion of the plan that-

\"(1) is specifically authorized under criteria established by an
Executive order to be kept secret in the interest of national defense or
foreign policy; and

\"(2) is properly classified pursuant to such Executive order.

\"(e) The functions and activities of this section shall be considered
to be inherently Governmental functions. The drafting of performance
plans under this section shall be performed only by Federal employees.

\"(f) For purposes of this section and sections 1116 through 1119, and
sections 9703 and 9704 the term-

\"(1) \'agency\' has the same meaning as such term is defined under
section 306(f) of title 5;

\"(2) \'outcome measure\' means an assessment of the results of a
program activity compared to its intended purpose;

\"(3) \'output measure\' means the tabulation, calculation, or recording
of activity or effort and can be expressed in a quantitative or
qualitative manner;

\"(4) \'performance goal\' means a target level of performance expressed
as a tangible, measurable objective, against which actual achievement
can be compared, including a goal expressed as a quantitative standard,
value, or rate;

\"(5) \'performance indicator\' means a particular value or
characteristic used to measure output or outcome;

\"(6) \'program activity\' means a specific activity or project as
listed in the program and financing schedules of the annual budget of
the United States Government; and

\"(7) \'program evaluation\' means an assessment, through objective
measurement and systematic analysis, of the manner and extent to which
Federal programs achieve intended objectives.

\"Sec. 1116. Program performance reports

\"(a) No later than March 31, 2000, and no later than March 31 of each
year thereafter, the head of each agency shall prepare and submit to the
President and the Congress, a report on program performance for the
previous fiscal year.

\"(b)(1) Each program performance report shall set forth the performance
indicators established in the agency performance plan under section
1115, along with the actual program performance achieved compared with
the performance goals expressed in the plan for that fiscal year.

\"(2) If performance goals are specified in an alternative form under
section 1115(b), the results of such program shall be described in
relation to such specifications, including whether the performance
failed to meet the criteria of a minimally effective or successful
program.

\"(c) The report for fiscal year 2000 shall include actual results for
the preceding fiscal year, the report for fiscal year 2001 shall include
actual results for the two preceding fiscal years, and the report for
fiscal year 2002 and all subsequent reports shall include actual results
for the three preceding fiscal years.

\"(d) Each report shall-

\"(1) review the success of achieving the performance goals of the
fiscal year;

\"(2) evaluate the performance plan for the current fiscal year relative
to the performance achieved toward the performance goals in the fiscal
year covered by the report;

\"(3) explain and describe, where a performance goal has not been met
(including when a program activity\'s performance is determined not to
have met the criteria of a successful program activity under section
1115(b)(1)(A)(ii) or a corresponding level of achievement if another
alternative form is used)-

\"(A) why the goal was not met;

\"(B) those plans and schedules for achieving the established
performance goal; and

\"(C) if the performance goal is impractical or infeasible, why that is
the case and what action is recommended;

\"(4) describe the use and assess the effectiveness in achieving
performance goals of any waiver under section 9703 of this title; and

\"(5) include the summary findings of those program evaluations
completed during the fiscal year covered by the report.

\"(e) An agency head may include all program performance information
required annually under this section in an annual financial statement
required under section 3515 if any such statement is submitted to the
Congress no later than March 31 of the applicable fiscal year.

\"(f) The functions and activities of this section shall be considered
to be inherently Governmental functions. The drafting of program
performance reports under this section shall be performed only by
Federal employees.

\"Sec. 1117. Exemption

\"The Director of the Office of Management and Budget may exempt from
the requirements of sections 1115 and 1116 of this title and section 306
of title 5, any agency with annual outlays of \$20,000,000 or less.\".

# Appendix C: Data Collection Instrument

# 

# 

[^1]: http://www.whitehouse.gov/omb/inforeg/iqg_oct2002.pdf