U.S. Department of Education

Indian Education Professional Development Grants Program: 

GPRA and Service Payback Data Collection

Section A

Office of Management and Budget

Clearance Package Supporting Statement

And Data Collection Instrument
i

TABLE OF CONTENTS

INTRODUCTION ....................................................................................................................

1

SECTION A. JUSTIFICATION

A.1 CIRCUMSTANCES MAKING THE COLLECTION OF INFORMATION 

NECESSARY ....................................................................................................................... 1

A.2 PURPOSES AND USES OF THE DATA ...................................................... 2

A.3 USE OF TECHNOLOGY TO REDUCE BURDEN....................................... 4

A.4 EFFORTS TO IDENTIFY DUPLICATION................................................... 4

A.5 METHODS TO MINIMIZE BURDEN ON SMALL ENTITIES................... 4

A.6 CONSEQUENCES OF NOT COLLECTING DATA..................................... 4

A.7 SPECIAL CIRCUMSTANCES....................................................................... 5

A.8 FEDERAL REGISTER COMMENTS AND 

PERSONS CONSULTED OUTSIDE THE AGENCY.......................................................... 5

A.9 PAYMENTS OR GIFTS ................................................................................. 5

A.10 ASSURANCES OF CONFIDENTIALITY .................................................... 5

A.11 JUSTIFICATION OF SENSITIVE QUESTIONS.......................................... 6

A.12 ESTIMATES OF HOUR BURDEN................................................................ 6

A.13 ESTIMATES OF COST BURDEN TO RESPONDENTS ............................. 7

A.14 ESTIMATE OF ANNUAL COST TO THE FEDERAL GOVERNMENT.... 8

A.15 PROGRAM CHANGES OR ADJUSTMENTS.............................................. 8

A.16 PLANS FOR TABULATION AND PUBLICATION OF RESULTS............ 8

A.17 APPROVAL TO NOT DISPLAY THE OMB EXPIRATION DATE............ 8

A.18 EXPLANATION OF EXCEPTIONS.............................................................. 8
1

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMSSION

INTRODUCTION

The Indian Education Professional Development (IE PD) Grants program provides grants to prepare and 

train Indians (i.e., American Indians/Alaska Natives) to serve as teachers and school administrators. The 

specific goals of the IE PD program are to: 1) increase the number of qualified individuals in professions 

that serve American Indians/Alaska Natives; 2) provide training to qualified American Indians/Alaska 

Natives to become teachers, administrators, teacher aides, social workers, and ancillary education 

personnel; and 3) improve the skills of those qualified American Indians/Alaska Natives who already

serve in these capacities. Individuals trained under this program must perform work related to their 

training and that benefits American Indian/Alaska Native people, or repay all or a portion of the cash 

value of training costs. 

The Office of Indian Education (OIE) is submitting this application to request extension approval to:

 collect from IE PD grantees contact and project service information for all IE PD participants; 

 collect employment and continuing education information from IE PD participants who are not in 

an approved and active deferment once they have exited the program; and 

 verify employment information on all IE PD participants who have exited the program and are 

working at a school in a target local educational agency (LEA), which is an LEA that enrolls 5 

percent or more American Indian/Alaska Native students.1

The proposed data collection serves three purposes. First, data from three sources (grantees, project 

participants, principals/LEA representatives2) are necessary to assess the performance of the IE PD 

program on its Government Performance Results Act (GPRA) measures (see Section A1, below). Second, 

data from all three sources are necessary to determine if IE PD participants are fulfilling the terms of their 

service/cash payback requirements. Finally, budget and project-specific performance data are collected 

from IE PD grantees for project-monitoring and compliance information. 

This application contains the justification for this request. The proposed forms and protocols contained in 

this package include the Semi-Annual Participant Report (SAPR), the Participant Follow-Up Protocol and 

the Employment Verification Form. All are contained in the appendices.

A. JUSTIFICATION

A1. Circumstances Making the Collection of Information Necessary

Information in the SAPR, the Participant Follow-Up Protocol, and the Employment Verification Form is 

being collected in compliance with Elementary and Secondary Education Act of 1965, as amended by the 

No Child Left Behind Act of 2001, Title VII, Part A, Subpart 2, Secs. 7121-7122; 20 U.S.C. 7441 - 7442 

(shown in appendix A), and the Government Performance Results Act (GPRA) of 1993, Section 4 (1115) 

(shown in appendix B). 

 

1

Service in a private school with a minimum American Indian and Alaska Native enrollment of 5 percent also 

counts as an approved setting. 

2

Participants who achieve employment as a teacher or vice principal will solicit employment verification from the 

principal at the school(s) of their employment. Participants who achieve employment as a principal will solicit 

employment verification from the appropriate representative at the LEA of their employment. 
2

There are six GPRA performance measures for the IE PD program. They are:

Measure 1 of 6: The percentage of participants in administrator preparation projects who become 

principals, vice principals, or school administrators in local educational agencies (LEAs) that enroll 5 

percent or more American Indian and Alaska Native students. 

Measure 2 of 6: The percentage of participants in teacher preparation projects who become teachers in 

LEAs that enroll 5 percent or more American Indian and Alaska Native students. 

Measure 3 of 6: The percentage of program participants who meet the definition of “Highly Qualified” in 

section 9101(23) of the ESEA. 

Measure 4 of 6: The percentage of program participants who complete their service requirement on 

schedule. 

Measure 5 of 6: The cost per individual who successfully completes an administrator preparation 

program, takes a position in a school district with at least 5 percent American Indian/Alaska Native 

enrollment, and completes the service requirement in such a school district.

Measure 6 of 6: The cost per individual who successfully completes a teacher preparation program, takes 

a position in a school district with at least 5 percent American Indian/Alaska Native enrollment, and 

completes the service requirement in such a school district.

Information also is collected to determine the value of each participant’s service or cash payback, which 

is a requirement of project participation. To determine this value, the IE PD program office must 

determine, for each project participant, the total training costs and number of months in training 

(information received from the grantee), and the status of service payback (information received from 

participants). These data cannot be collected from other sources. Information must be received on all 

project participants.

The SAPR collects detailed information on participants that will allow individual follow up by the IE PD 

program office. Participant contact information, participant alternative contact information, participant 

project status and participant placement status, along with budget information and project-specific 

objectives and performance measures, are reported by grantees in the SAPR at the close of the 2nd and 4

th

quarters of the project year. OIE also must receive follow up from individual participants and their 

principals or LEA representatives (if the participant is employed in a target LEA). Data from all three 

sources are required for GPRA reporting and service payback monitoring. 

A2. Purposes and Uses of the Data

There are three primary purposes for the data that are being collected. The first use is to fulfill GPRA

reporting requirements. In 1993, GPRA was passed that requires federally funded agencies to develop 

and implement an accountability system based on performance measurement. Grantees are required to 

report on their progress toward meeting the objectives and goals established for each ED grant program. 

However, IE PD needs data directly from participants and their principals/LEA representatives in addition 

to grantee data for GPRA reporting. 
3

The second use of the data is to ensure participants complete a payback requirement that equals the 

number of months in training (for service payback) or the amount of training costs incurred (for cash 

payback). To fulfill service payback, participants are required to:

a) achieve placement in a LEA with at least 5 percent American Indian/Alaska Native students; 

b) work in a subject area in which they received training through project services; and 

c) continue their placement for a duration of time equal to that of time owed for payback in months. 

If the participant fails to complete the PD training or fails to complete the service payback requirement, 

the participant is required to pay back all or a portion of their training costs. Training costs are the total 

dollar amount the participant received in tuition, fees, books, childcare, or other expenses. Participants 

may defer their payback requirements if they are enrolled as full-time students in an approved education 

program at an accredited institution of higher education. The participant must submit a written request 

for deferment to the program office that includes the name of the institution, a copy of the admission 

letter, the degree being sought, and projected date of completion. After deferment has been granted, the 

participant must provide proof of ongoing full-time student status. The program office must receive 

information from the grantee that allows follow up with the participant. The program office also must 

receive information from the participant’s principal or LEA representative with regard to placement, 

position, “Highly Qualified” status for those teaching, and post-project employment duration. 

The third use of the data is to collect contact, budget and project-specific performance information from 

grantees for project monitoring. As multi-year award recipients, IE PD grantees must provide the most 

current performance and financial expenditure information to ED as directed by the Secretary under 34 

CFR 75.118 for continued funding. 

Data collection 

To fulfill all of these purposes, the data collection involves grantee, participant, and principal/LEA 

representative components. In the grantee component, all IE PD grantees will submit semi-annually

contact and service information for all IE PD participants using the SAPR, which is found in Appendix C. 

For the first SAPR submission, grantees will provide information on all IE PD participants ever enrolled 

in the project since the start of the grant. For subsequent SAPR submissions, grantees will update 

information on participants from the previous submission (including any leaves of absences or other exits) 

and add entries for new participants. Grantees will report this information on all participants for the 

length of the grant award. Grantees will report this information twice a year at the end of the 2

nd and 4th

project quarters. Grantees will also provide budget and project-specific performance information on the 

SAPR.

In the participant component, IE PD participants will initiate contact with IE PD staff within 6 months of 

exiting the PD program and every 6 months thereafter for the length of their service payback period to 

report their employment and continuing education information. Note that all participants are supposed to 

report their employment status to IE PD as part of their service payback requirement. IE PD staff will 

follow up with participants if they fail to contact OIE. We expect that participants may initiate contact 

with IE PD staff by phone or email, and IE PD staff will follow up primarily by phone or email. 

Regardless of how contact is established, the IE PD staff will use the Participant Follow-Up Protocol to 

obtain employment and continuing education information (see Appendix D). 

Data from participants will be collected twice a year to reduce the possibility of losing contact with 

participants over time. Loss of contact can cause problems if a participant is supposed to enter cash 

payback but cannot be found or if the participant is actually fulfilling a service payback requirement 

without the program office’s knowledge.
4

In the principal/LEA representative component, participants working in an LEA enrolling 5 percent or 

more of the target population will give the Employment Verification form to their principal or LEA 

representative to complete. Through this form, the principal/LEA representative will verify employment 

information and identify whether a participant who is teaching is Highly Qualified in the subject(s) 

taught. This information is required for GPRA measure 3 (see Section A1, above). The principal/LEA 

representative will send the completed Employment Verification Form directly to OIE. The participant 

must initiate the employment verification process every 6 months for the length of his or her service 

payback requirement. The Employment Verification Form is found in Appendix E. 

The IE PD staff will use the data from all three components to create a database with participant contact, 

project service, continuing education, employment, and service payback information. The database will 

be updated as needed throughout the length of the participant’s IE PD project training and service 

payback experience. 

Uses of the data 

The IE PD program office staff will use this database to report on the program’s GPRA measures to the 

U.S. Department of Education’s (ED’s) Budget Service. The aggregated performance data will also be 

included in ED’s Annual Program Performance Report. 

IE PD program office staff also will use the database to determine whether participants fulfill their service 

payback requirements. If a participant does not fulfill his/her service payback requirement, the collected 

data will help IE PD staff determine the cash amount an individual must pay back. These are essential 

aspects of project oversight, such that the program office can ensure that project participants are fulfilling

requirements stipulated in program application materials. Projects bear the responsibility of informing 

participants of their responsibilities and providing participants with adequate information such that 

participants can voluntarily contact the program office upon exiting project services. Without participant 

follow up, the program office can only determine if participants are fulfilling their service requirement if

the participants voluntarily maintain contact with the program office. This approach will likely 

result in very poor data regarding the fulfillment of service requirements and program performance. 

A3. Use of Technology to Reduce Burden

The SAPR will be submitted through ED’s e-Reports system at http://e-grants.gov, which allows grantees 

to submit this information over the Internet. 

A4. Efforts to Identify Duplication

Participant information will be updated on a semi-annual basis but there will be no duplication of 

reporting efforts per participant, grantee or principal/LEA representative. The information requested for 

this reporting is not collected or reported elsewhere.

A5. Methods to Minimize Burden on Small Entities

The forms were designed to solicit only the information necessary to respond to program and GPRA 

requirements. Thus, the burden of reporting is minimized to only those elements necessary to meet 

federal requirements for budget and program activity data. 

A6. Consequences of Not Collecting Data

Annual or periodic performance reporting is stipulated in GPRA 1993, Section 4. The SAPR form will 
5

provide a standardized means for grantees to report on the status of individual participants as is necessary 

for the program office to complete GPRA data collection and reporting. Without these data and the data 

from the Participant Follow-Up Protocol and Employment Verification Form, the program office does not 

have a reliable and consistent means of collecting GPRA-related data from individual participants. 

Participant contact, in turn, is necessary to collect data related to participant employment--without 

participant follow up, the program office may not know where participants are employed. The 

verification of employment and determination of Highly Qualified status for teachers is collected from the 

principal/representative of the schools/LEAs in which participants find employment. 

In addition, participant follow-up is necessary for the program office to monitor service payback 

requirements. The only way that the program office can monitor completion of service requirements 

equal in value to that of the months in training is through systematic and on-going follow up with 

participants and their employers (i.e., the principal or LEA representative). 

The consequence of not collecting the data, conducting follow up with participants, and receiving 

employment verification from principal/LEA representatives is a failure to ensure all participants are 

complying with statutory requirements. 

A7. Special Circumstances 

There are no special circumstances that would require the collection to be conducted in a manner 

inconsistent with OMB guidelines. 

A8. Federal Register Comments and Persons Consulted Outside the Agency

We will publish the 60-day Federal Register notice and provide this document when available. 

[INSERT FEDERAL REGISTER NOTICE HERE.]

A9. Payments or Gifts 

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

A10. Assurances of Confidentiality

All data collection activities will be conducted in full compliance with ED regulations. Data 

collection activities will be conducted in compliance with The Privacy Act of 1974, P.L. 93-579, 

5 USC 552 a; the “Buckley Amendment,” Family Educational and Privacy Act of 1974, 20 USC 

1232 g; The Freedom of Information Act, 5 USC 522; and related regulations, including but not 

limited to: 41 CFR Part 1-1 and 45 CFR Part 5b and, as appropriate, the Federal common rule or 

ED’s final regulations on the protection of human research participants. This is to maintain the 

confidentiality of data obtained on private persons and to protect the rights and welfare of human 

research subjects as contained in ED regulations. 

Materials received from grantees will contain participant name and contact information, participant social 

security number (SSN), participant date of birth, an alternate contact’s name and contact information, and 

information on the participant’s participation in project training. OIE strongly recommends that grantees 

a) inform participants that their information will be kept confidential and b) request a written release from 

participants to provide these data to OIE. However, participant follow up also is a condition of project 

participation; if participants fail to comply with requirements to initiate contact with OIE, OIE must have 

some recourse to initiate contact with all participants and thus acquire data relevant for GPRA reporting 
6

and project payback requirements. Personally Identifiable Information will not be collected until a 

System of Records Notice has published. 

Project staff will adhere to the regulations and laws regarding the confidentiality of individually 

identifiable information. OIE’s digital database is limited to OIE staff members needing access for data 

entry or management purposes and limits access according to differing levels of permission. The 

database is operated under Microsoft ACCESS and is backed up daily via ED’s default server practices. 

Should any issue arise, back up files may be accessed for recovery purposes. Payback files are 

maintained in a locked cabinet accessible by only those who have the authority to work with these files. 

Information submitted using the Grants Administration Payment System (GAPS) is protected in two 

ways. First, all access to GAPS is password protected with passwords changed every three months. 

Second, access to passwords is selectively granted to individuals based on rank and responsibility.

A11. Justification of Sensitive Questions

Questions regarding SSN, employment status, and service payback status may be considered sensitive. 

However, the employment and service payback status questions are necessary to directly respond to 

GPRA measures and program requirements for service payback. SSN is needed to track individuals who 

fail to keep in contact with the IE PD program office and are turned over to ED’s Debt Management 

Group. The Debt Management Group needs SSN to try to locate participants in other databases including 

Internal Revenue Service databases. 

A12. Estimates of Hour Burden 

Table A-1 presents maximum annual burden estimates for grantees and participants. The program office 

estimated that 36 active grantees and 1,020 participants would be affected. 

At each semi-annual data collection, the number of participants followed up and the number of 

principals/LEA representatives verifying employment will vary depending on when participants exit 

project training. For the purposes of estimating burden, we present the maximum burden estimate by 

assuming that all of the estimated 1020 participants will be contacted semi-annually and all participants 

will be employed in target LEAs.

The burden for grantees of completing the portion of the SAPR without participant data is estimated at 20 

hours per grantee per semi-annual collection. We anticipate that grantees will require at least 2 hours per 

participant to complete the portion of the SAPR with participant data. 

For participants, follow up begins within 6 months of completing or exiting project services. The number 

of participants requiring follow up in any given project year may range from zero per project (if all 

participants are still enrolled in project services) to as many as 1020 participants across all projects. We 

anticipate that participant burden for follow up will be 30 minutes every 6 months.

For principals/LEA representatives, the participant will initiate employment verification within 6 months 

of a participant’s completion of project services and placement with the LEA. Some participants either 

do not stay employed in education or enter deferment due to approved on-going education. Therefore the 

number of principals/LEA representatives asked to provide verification may be lower than the number of 

participants that exited the IE PD training. We anticipate the principal/LEA representative burden to be 

one hour per participant every 6 months. 

For burden estimates, we assume that grantee administrators and principals/LEA representatives have an 
7

hourly rate of $50. We assume an average hourly rate of $37.50 for participants, understanding that some 

participants may be earning more as administrators, and some may be earning less as teachers or while in 

deferment. Given these rates and the hour estimates above, the maximum estimated annual burden is 

$416,250 across all grantees, participants, and principals/LEA representatives. 

Table A-1. Maximum Annual Burden Estimates, by Data Source

Data Source

Estimated

Number of 

Participants 

Estimated SemiAnnual Burden 

per Participant 

(in Hours)

Estimated SemiAnnual Burden

(in Hours)

Estimated 

Semi-Annual 

Cost

(in Dollars)

Estimated Total 

Annual Cost

(in Dollars)

Grantees: Budget & 

project-specific 

performance data for 

SAPR

36 grantees 20 720 $36,0001$72,0001

Participants: follow up 

with IE program office

1,020

participants .5 510 $19,1252

$38,250

2

Principals/LEA 

representatives: 

completion of 

Employment Verification 

Form

1,020

participants 

employed in 

schools3

1 1,020 $51,0001$102,0001

Totals 2076 2250 $208,125 $416,250

1 Based on an estimated hourly rate of $50 for grantee administrators and principals/LEA representatives.

2 Based on an estimated average hourly rate of $37.50 for participants.

3Assumes that all participants are employed in schools in target LEAs

A13. Estimate of Cost Burden to Respondents

We do not anticipate additional costs to respondents or record-keepers resulting from each collection 

other than that already reported in A12 and A14, including capital or start-up costs, or operation, 

maintenance, or purchase of services. 

It is a participant requirement to contact OIE upon completion or exit from training. Those participants 

who comply with this requirement also bear the cost of instigating communication with OIE. Some 

participants, depending on the technology used, may continue to bear the cost of communication (e.g., 

cell phone or email service costs).
8

A14. Estimate of Annual Cost to the Federal Government

The IE PD program office staff will receive data from grantees, participants and principals or LEA 

representatives. The IE PD program office also will enter and manage all data related to IE PD GPRA

measures and service payback status. 

The IE PD program office maintains appropriate staff whose function is to acquire and maintain GPRA

data for this program from all three sources. This staff position is a GS 5 position, which, in 2009, ranges

from $33,269 to $43,251 in annual salary for the Washington D.C. locality.

A15. Program Changes or Adjustments

This request does not constitute a change or adjustment; an old burden is not being revised. Rather, this is 

a request for a new program requirement.

A16. Plans for Tabulation and Publication of Results 

OIE will maintain and update participant information in an ED database. The function of this database is 

to facilitate the tracking and follow up with individual IE PD participants. Data will be entered by IE PD 

program staff and maintained by the same staff. Follow up also will be performed by IE PD program 

staff with the results of follow up entered into the database. The database will be used on, at least, an 

annual basis to create GPRA reports and to monitor the fulfillment of participant service payback. 

There currently are no plans for publication beyond reporting results to ED’s Budget Service for 

compliance with GPRA and publication in ED’s Annual Program Performance Report. Should this 

opportunity arise, the program office will follow OMB recommended steps to ensure information quality. 

Following this, the program office will engage in peer review by ED colleagues as well as experts in the 

field for any publication of analyses resulting from the data collection instruments proposed herein.

A17. Approval to Not Display the OMB Expiration Date

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

A18. Explanation of Exceptions 

There are no exceptions to the certification statement.