Talent Search and Educational Opportunity Centers Programs

**Request for Approval under the Paperwork Reduction Act and 5 CFR
1320**

# Supporting Statement for the TS and EOC Annual Performance Report Form

## A. Justification

1\. The Department of Education (Department) is requesting approval of
the current performance report form that will expire on September 30,
2008 (OMB No. 1840-0561), with revisions, to collect data under the
Talent Search (TS) and Educational Opportunity Centers (EOC) programs.

In this revision, the Department has updated the form and instructions
to reflect the final guidance on maintaining, collecting, and reporting
racial and ethnic data. Since the Department is interested in collecting
the same type of data for the 4-year project cycle, no major revisions
were made to the collection.

The TS and EOC programs are two of the eight Federal TRIO programs that
provide federal financial assistance in the form of discretionary grants
to institutions of higher education and education agencies to increase
participation and completion rates of low-income and first-generation
college students in the academic pipeline. The specific goal of the TS
and EOC programs is to help youth and adults from disadvantaged
backgrounds complete secondary education and enroll in programs of
postsecondary education (20 U.S.C. 1070a).

The information that grantees submit in the performance report allows
TRIO to assess annually each grantee\'s progress in meeting the
project\'s approved goals and objectives. The performance report data
are compared with the project\'s approved objectives to determine the
project\'s accomplishments, to make decisions regarding whether funding
should be continued, and to award \"prior experience\" points. The
regulations for these programs provide for awarding up to 15 points for
prior experience (34 CR 643.22 for TS; 644.22 for EOC). During a
competition for new grant awards, the prior experience points are added
to the average of the field reader scores to arrive at a total score for
each application. Funding recommendations and decisions are primarily
based on the rank order of applications on the slate; therefore,
assessment of prior experience points, based on data in the annual
performance report, is a crucial part of the overall application
process.

Further, this performance report form is the main source of data for the
Department\'s response for these two programs to the requirements of the
Government Performance and Results Act (GPRA). In the Department\'s FY
2008 Annual Program Performance Plan, the program goal for the Federal
TRIO programs is to \"Increase the percentage of low-income,
first-generation college students who successfully pursue postsecondary
education opportunities.\"

The Department collects information from TS and EOC grantees under the
authority of Title IV, Part A, Subpart 2, Chapter 1, Section 402B and F
of the Higher Education Act of 1965, as amended, the program regulations
in 34 CFR 643 and 644, and the Education Department General
Administrative Regulations (EDGAR), in 34 CFR 74.51, 75.720, and 75.732.
Copies of the authorizing statute and the programs\' regulations are
attached.

2\. The Department uses the data collected to (a) evaluate projects\'
accomplishments, (b) determine the number of prior experience points to
be awarded to current grantees, and (c) aid in compliance monitoring
(e.g., to determine whether grantees are in compliance with the
selection requirements for project participants \[34 CFR 643.3 and
644.3\]).

In addition, TRIO uses the annual performance reports to produce
program-level data for annual reporting, budget submissions to OMB,
Congressional hearings and inquiries, and responding to inquiries from
higher education interest groups and the general public. Without this
data collection, the Federal TRIO programs would be unable to comply
with the prior experience component of the law and to respond to GPRA
requirements.

With performance report data submitted in fall 2005, TRIO staff members
calculated the prior experience points each grantee had earned\--a
critical element in determining which applicants received grant awards
for periods beginning fall 2006. In fall 2006, ED relied exclusively on
performance report data to determine, for GPRA purposes, percentages of
EOC and TS participants who had enrolled in postsecondary education.

3\. Since 1999, TS and EOC grantees have used collected data in
computerized data systems and have submitted that data via a Web-based
software application that allows them to enter data online and submit
the report via the Web. While 56 percent of grantees submitted reports
electronically in 1999, now all grantees do so.

The data collected are summary information, not data on individual
participants; thus the reports are a low-level security risk.
Nonetheless, the Web site is secured to ensure that the data are seen
only by authorized individuals and are protected from network hackers.
Further, online data edits are in place to ensure the accuracy and
integrity of the data submitted.

4\. Since the information grantees submit in their performance reports
is unique to each project, no duplication exists. No other instrument is
available to collect the information that the program needs to assess
prior experience or program outcomes. The data collected in the annual
performance reports are fundamental to these programs.

5\. This information collection does not affect small businesses or
other small entities.

6\. As indicated above, if the information were not collected, the
Department would be unable to assess grantees\' performance, to follow
regulations governing award of new grants, and to report on each program
as a whole. As grantees\' and programs\' performance must be assessed
annually, so must the reports be submitted each year.

7\. This information collection will not be conducted in a manner cited
in item #7 of the instructions for the Supporting Statement (revised
1/97).

8\. The Department\'s Regulatory Information Management Group will
solicit comments on this information collection in the [Federal
Register]{.underline}, pursuant to 5 CFR 1320.8(d), upon submitting the
collection to OMB. A summary of any comments received will be shared
with OMB. The Department also solicits informal views and comments from
persons outside the Department during yearly national and regional
educational conferences. The Department will publish 60-day and 30-day
[Federal Register]{.underline} notices to allow public comment on this
collection.

9\. The Department will not provide payment or gifts to respondents.

10\. No assurances of confidentiality are provided to the respondents,
except as provided by the Privacy Act. There are no statutory or
regulatory requirements for assurances of confidentiality.

11\. The performance report form does not include questions about sexual
behavior and attitudes, religious beliefs, or other items that are
commonly considered sensitive and private.

12\. Estimated hour burden of this collection of information is six
hours (5.5 hours for professional staff to gather the information using
computerized technology and 0.5 hours for clerical staff to enter the
staff into the Web-based form). We estimate approximately 596
respondents (471 TS and 125 EOC). The performance reports are submitted
annually.

Estimated number of respondents 596

Estimated preparation time 6

**Total estimated burden hours 3,576**

Estimated burden: Six hours per respondent.

*Estimated annualized cost to respondents*: Most of the costs of this
data collection are those of the Federal government, since the
respondents are project staff paid for the most part with Federal grant
funds. Nonetheless, the annual cost to the grantee to respond to this
data collection is estimated as follows:

Professional staff

(596 respondents X 5.5 hours @ \$35 per hour) \$114,730

Clerical staff

(596 clerical staff members X 0.5 hours @ \$18 per hour) 5,364

## Total estimated cost to respondents \$120,094

13\. There are no other costs to the respondents. Grantees are required
by program regulations to collect and maintain this information. The
costs to transmit the data electronically via the Web are customary and
usual business practices.

14\. *Estimated annual costs to the Federal government*

The largest portion of the Government\'s cost is borne directly by the
Department in designing the report form; securing clearance; and
collecting, aggregating, and disseminating the information.

Professional staff to update report form and prepare clearance package:

\$55 per hour X 40 hours \$2,200

Overhead costs (facilities, administration, accrual of leave, and

fringe benefits; estimated at 50% of salary) 800

Clerical staff to type, route, and copy report form:

\$18 per hour X 10 hours 180

Overhead costs (50% of salary) 90

Other Department staff to review and approve the request:

\$50 per hour X 6 hours 300

Overhead costs (50% of salary) 150

OMB review (estimated):

\$50 per hour X 8 hours 400

Overhead costs (50% of salary) 200

Posting performance report application to World Wide Web:

\$40 per hour X 2 hours 80

Overhead costs (50% of salary) 40

Annual updates to Web application, Web site hosting, help desk,

and data processing (contractor\'s costs) 70,000

Analyses of data and preparation of national summary reports and

individual project data (contractor costs) 90,000

Professional staff to review and edit reports for dissemination:

\$40 per hour X 40 hours 1,600

Overhead costs (50% of salary) 800

Printing and mailing of reports [10,500]{.underline}

## Total \$177,340

15\. The total burden hours reported in item #16 of Part I: Information
Request reflects a decrease because of a smaller number of respondents
than those reported previously; the burden hour per respondent is
unchanged. The estimated cost to the Federal government (item #14) is
unchanged.

16\. Collected information will be analyzed annually to determine if
each grantee is meeting its approved goals and objectives and to award
prior experience points. Performance measures and efficiency measures
for the two programs, based on data conveyed in grantees\' annual
performance reports, are disseminated in the Department\'s Annual
Program Performance Plan. Over the next few years, the Department plans
to release on the Web, data on performance and efficiency measures *at
the grantee level*; this more detailed reporting will be possible due to
improvements in accuracy that the program anticipates will result from
incorporating the new standard objectives into the report form.

The Department has prepared and disseminated three reports on the TS and
EOC programs, both printed and on the Web, covering demographic
information on grantees and participants and program outcomes (e.g.,
postsecondary enrollment rates). The purpose for these reports is to
share national information at the program level with project staff and,
as appropriate, with members of Congress and the larger education
community. For the future, TRIO staff members anticipate producing one
concise but detailed report per grant cycle that will cover both
demographics and outcomes (with comparisons to the previous cycle) and
may be released both in print and electronic form. The program also aims
to provide timely, annual release, via the Web, of a set of tables
conveying the most important data about the program. (The reports
published to date are available at
<http://www.ed.gov/programs/triotalent/resources.html> and
<http://www.ed.gov/programs/trioeoc/resources.html>.)

17\. This report form and the Web site will display the expiration date
for OMB\'s approval of the information collection.

18\. There are no exceptions to the certification statement.

## B. Collections of Information Employing Statistical Methods

This collection does not employ statistical methods.