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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. Attach 

a copy of the appropriate section of each statute and regulation mandating or 

authorizing the collection of information.

The Education Department General Administrative Regulations (EDGAR) contain several 

requirements that grantees maintain certain types of records related to their grants and to 

report or submit certain information to the Department. The specific EDGAR recordkeeping 

and reporting requirements that are part of this information collection package are described 

in Table I (attached). These requirements are necessary for the effective administration and 

monitoring of grant projects. 

2. Indicate how, by whom, and for what purpose the information is to be used. Except 

for a new collection, indicate the actual use the agency has made of the information 

received from the current collection.

As there are several program recordkeeping and reporting requirements under this 

information collection a table has been added to provide a detailed description of each ED 

recordkeeping and reporting requirement in the attached Table I. 

3. Describe whether, and to what extent, the collection of information involves the use 

of automated, electronic, mechanical, or other technological collection techniques or 

forms of information technology, e.g. permitting electronic submission of responses, 

and the basis for the decision of adopting this means of collection. Also describe any 

consideration of using information technology to reduce burden.

The Department’s grant management system, G5, gives Project Directors the ability to submit 

administrative changes to their grant awards. The following types of changes are available: 

DUNS/SSN, address, key personnel, Project Director name and address, dates (no-cost time 

extensions), certifying representative, and others. The submission of the aforementioned 

administrative requests prompts e-mail notification to the ED Program Manager of the 

administrative request. The creation and printing and signing of a Grant Award Notification 

(GAN) and subsequent mailing of copies of the GAN signify approval of the administrative 
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request. The G-5 Grants Management System also has additional grants management, 

monitoring and administrative capabilities. 

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use of the purposes described in Item 

2 above.

The information that the grantees must maintain or submit to the Department under the 

EDGAR recordkeeping and reporting requirements included in Table I are unique to each 

individual grant project and cannot be obtained from any other sources. This information 

would not have been submitted to the Department previously for any other purpose.

5. If the collection of information impacts small businesses or other small entities (Item 

8b of IC Data Part 2), describe any methods used to minimize burden.

Similar methods as described in number 3 also apply to methods used to minimize burden that 

impacts small businesses or other small entities. The Department’s grant management system, 

G5 gives Project Directors the ability to submit administrative changes to their grant awards. 

The following types of changes are available: DUNS/SSN, address, key personnel, Project 

Director name and address, dates (no-cost time extensions), certifying representative, and 

others. The submission of the aforementioned administrative requests prompts e-mail 

notification to the ED Program Manager of the administrative request. The creation and 

printing and signing of a Grant Award Notification (GAN) and subsequent mailing of copies of 

the GAN signify approval of the administrative request. 

6. Describe the consequences to Federal program or policy activities if the collection is 

not conducted or is conducted less frequently, as well as any technical or legal 

obstacles to reducing burden.

If this information collection is not conducted or conducted less frequently, it would hinder the 

ability of ED Program Staff to effectively monitor, provide guidance and technical assistance to 

grantees. The goal of monitoring is to establish partnerships with grantees that allow for 

flexibility in local decision-making, in conjunction with a results-oriented approach to program 

management that demonstrates excellence, accountability, and successful performance 

outcomes. Monitoring must also address ED’s fiduciary responsibility to ensure the grantee’s 

legal and fiscal compliance and to protect against fraud, waste, and abuse.

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner:

 requiring respondents to report information to the agency more often than 

quarterly;
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 requiring respondents to prepare a written response to a collection of information 

in fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any 

document;

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed 

and approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority 

established in statute or regulation, that is not supported by disclosure and data 

security policies that are consistent with the pledge, or which unnecessarily 

impedes sharing of data with other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate tht it has instituted procedures to 

protect the information’s confidentiality to the extent permitted by law.

The information will not be collected in a manner inconsistent with the general information 

collection guidelines in 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in 

the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting 

comments on the information collection prior to submission to OMB. Summarize 

public comments received in response to that notice and describe actions taken by 

the agency in response to these comments. Specifically address comments 

received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on 

the availability of data, frequency of collection, the clarity of instruction and record 

keeping, disclosure, or reporting format (if any), and on the data elements to be 

recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained 

or those who must compile records should occur at least once every 3 years – even 

if the collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.
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The Department published a 60 day notice on March 11, 2014 (79 FR 13647) A 30-day Federal 

Register notice was published. There were no public comments.

Comments were also provided through annual national conferences, regional and state 

meetings, frequent monitoring contacts with applicants/grantees (i.e., State Education 

Agencies (SEA’s), Local Education Agencies (LEA’s), Tribal Governments, Institutions of Higher 

Education (IHE’s) and Non-Profit Organizations [NPO’s] ), which are the entities affected by the 

information collection. Individuals have expressed their views on the availability of data, 

frequency of collection, the clarity of instructions and disclosure of reporting format, and on 

the data elements to be disclosed or reported. These consultations have been effective in 

resolving any major problems related to the information collection.

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees.

There are no payments or gifts to respondents other than the allocation of federal funds that 

result from the information collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for 

the assurance in statute, regulation, or agency policy.

ED is not requesting any confidential information in this collection; therefore no assurances of 

confidentiality are required.

11. Provide additional justification for any questions of a sensitive nature, such as 

sexual behavior and attitudes, religious beliefs, and other matters that are commonly 

considered private. The justification should include the reasons why the agency 

considers the questions necessary, the specific uses to be made of the information, the 

explanation to be given to persons from whom the information is requested, and any 

steps to be taken to obtain their consent.

This information collection does not include information of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The 

statement should :

 Indicate the number of respondents, frequency of response, annual hour 

burden, and an explanation of how the burden was estimated. Unless 

directed to do so, agencies should not conduct special surveys to obtain 

information on which to base hour burden estimates. Consultation with a 

sample (fewer than 10) of potential respondents is desirable. If the hour 

burden on respondents is expected to vary widely because of differences in 

activity, size, or complexity, show the range of estimated hour burden, and 
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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 16 of 

IC Data Part 1.

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate 

categories. The cost of contracting out or paying outside parties for 

information collection activities should not be included here. Instead, this cost 

should not be included in Item 14.

Approximately 4988 respondents will be required to maintain records or submit reports in 

accordance with the recordkeeping and reporting requirements contained in the Education 

Department General Administrative Regulations (EDGAR). See the attached table for the 

burden hour calculation for each EDGAR recordkeeping and reporting requirement.

Total Annual Burden Hours to Respondents for the EDGAR Recordkeeping and Reporting 

Requirements = 22,448 burden hours 

State, Local and Tribal affected public:

Total Recordkeeping burden hours: 17,460

Total Reporting burden hours: 2,744

Private Sector-Not or Profit Institution:

Total Recordkeeping burden hours: 1940

Total Reporting burden hours: 304

13. Provide an estimate of the total annual cost burden to respondents or record 

keepers resulting from the collection of information. (Do not include the cost of any 

hour burden shown in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and 

start-up cost component (annualized over its expected useful life); and (b) a total 

operation and maintenance and purchase of services component. The estimates 

should take into account costs associated with generating, maintaining, and 

disclosing or providing the information. Include descriptions of methods used to 

estimate major cost factors including system and technology acquisition, 

expected useful life of capital equipment, the discount rate(s), and the time 

period over which costs will be incurred. Capital and start-up costs include, 

among other items, preparations for collecting information such as purchasing 
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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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested : $ .00

There are no start-up costs.

Total Annual Cost Burden to Respondents for the EDGAR Recordkeeping and Reporting 

Requirements

22,448 total burden hours (recordkeeping and reporting) X $25/hour = $561,200

14. Provide estimates of annualized cost to the Federal government. Also, provide a 

description of the method used to estimate cost, which should include quantification of 

hours, operational expenses (such as equipment, overhead, printing, and support staff), 

and any other expense that would not have been incurred without this collection of 

information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in 

a single table.

Total Annual Cost to the Federal Government for EDGAR Reporting Requirements: $205,805

The total annual cost is based on the following:

EDGAR Reporting Requirements: 1 hour per response X 4988responses X $41.26/per hour 

(average DC- area GS-12 hourly rate) = $205,805
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15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

The burden hours for the EDGAR recordkeeping and reporting requirements have a decreased 

adjustment of 20,380 hours. This decrease is an overall reflection of the actual number of time 

extensions notifications received by ED in FY 2013 (which was smaller than the number 

estimated in FY 2010) and a decrease in the number of awards awarded to IHEs, NPOs and 

Hospitals in FY 2013. 

16. For collections of information whose results will be published, outline plans for 

tabulation and publication. Address any complex analytical techniques that will be 

used. Provide the time schedule for the entire project, including beginning and ending 

dates of the collection of information, completion of report, publication dates, and other 

actions.

No plans exist to publish the results of this information collection.

17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

We are not seeking approval to not display the expiration date for this information collection.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

There are no exceptions to the certification statement.