**Supporting Statement for the Application for Grants under the**  **Training Program f** 

**or Federal TRIO Programs**  **Higher Education Act of 1965, as amended, Title IV -**  **A**
**A. Justification** 
1. Explain the circumstances that make the collection of information nec essary. I dentify an y legal or administrative requirements that necessitate the collection. Attach a hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information, or you may

provide a valid URL link or paste the applicable section. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change). If revised, briefl y specify the changes. If a rulemaking is involved, make note of the se ctions or changed sections, if applicable. The U.S. Department of Education is requesting a reinstatement with out change of a previously

approved collection to make new grants under the Training (Training) Program. The previous collection was discontinue d and a pproval will allow the department to use the application to award new grants and collect data under the Training Program. Through a grant competition, funds are awarded to institutions of higher education and other public and private nonprofit in stitutions and organizations to support training to enhance the skills and expertise of project directors and staff employed in the Federal TRI O Programs. Funds may

be used for conferences, seminars, internships, workshops, or the publication of manuals. T raining topics are based on priorities established by the Secretary of Education and announced in Federal Register notices inviting applications. Annual training is provided via electronic and live conferences and webinars; internships, seminars, workshop s, and the publication of manuals designed to improve the operation of TRI O projects. These trainings are carried out in the various regions to ensure that growth opportunities are available to all TRI O personnel in the local projects. The topics covered i n the trainings include but are not limited to legislative and regulatory requirements; assisting students in receiving adequate financial aid; the design and operation of model programs; the use of appropriate educational technology ; and strategies for re cruiting and serving hard to reach populations. This application would include required and permissible services or activities; outcome criteria used in assessing prior experience; selection criteria; and a description of the processes and procedures for the second review of unsuccessful applications. The Training program grant competition is authorized by the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a

- 14

. http://www.ecfr.gov/cgi

- bin/text

idx?c=ecfr&sid=b9a18b9cca8ba8627ff76f3ad37f72f6&rgn=div5&view=text&node=34:3.1.32

.1.15&idno=34 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. The application package requests programmatic and budgetary in formation needed to evaluate new applications and make funding decisions based on the authorizing statute, program regulations, and EDGAR. Failure to collect this information would prevent the awarding of appropriated funds; essential information would n ot be available for evaluating the applications in accordance with the statute and regulations. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collectio n 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 given to using technology

to reduce burden. For fis cal year 201 4 , as a part of the Department’s goal to increase the electronic submission of applications, applications for grants under the Training p rogram will be submitted electronically

via the Grants.gov portal. We estimate that the Department will re ceive 100 percent of the applications electronically

. The application package has been prepared in a format for easier and faster posting of information on the Web. Prospective applicants will be able to view and download the application through the FIND function on Grants.gov at http://www.Grants.Gov

. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information already available cannot be used or modified for use for the purposes descri bed in Item 2 above. Since the information submitted in the application is unique to each respondent, no duplication exists as far as can be determined. There is no other collection instrument available to collect the information that is being requested. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independentl y owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not
- for

- profit enterprise that is independentl y owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city , county , town, township, school district, or special district with a population of less than 50,000. This information collection does not involve small businesses or other small entities. 6. Describe the consequences to Federal program or policy activities if the collection is not3

conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. If the collection is not conducted or is collected less frequentl y, the Department cannot meet its grant making responsibi lities, including the publication of closing date notices, providing technical assistance to potential applicants, conducting peer reviews of grant applications, transmitting slates with funding recommendations to Department officials for approval, and making grant awards. The Department needs to make grant applications available to its constituencies to give eligible applicants time to develop and submit applications, and to make new fiscal year grant awards in a timely

manner. 7. Explain any

spec ial circumstances that would cause an information collection to be conducted in a manner: requiring respondents to report information to the agency more often than quarterl y; requiring respondents to prepare a written response to a collection of inf ormation in fewer than 30 day s 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 ye ars; 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 ha s 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 that unnecessaril y i mpedes 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 institut ed procedures to protect the information’s confidentiality to the extent permitted by law. No information will be collected in the manner covered under any of the special circumstances outlined. 8. As applicable, state that the Department has publishe d the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection prior to4

submission to OMB. Summarize public comments received in response to that notice and describe actions taken b y the agency i n 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 instruct ion and record keeping, disclosure, or reporting format (if an y), 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 reco rds 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. Th e Department will solicit informal views and comments from persons outside the Department during a pre - application workshop for Training as mandated b y statute. The Department will publish a 30

- day Federal Register notice allowing public comment on this c ollection. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification. The Department will not provide any paym ents or gifts to respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy . If personally

identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Pl ease provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be prov ided. If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data. There is no assurance of confidentiality

. 11. Provide additional justification for an y 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 application does not include questions about sexual behavior and attitudes, religious beliefs, or other items that are commonl y considered sensitive and private.5

12. Provide estimates of the hour burden of the collection of informatio n. The statement should: Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for

- profit, private sector

– not
- for

- profit institutions, farms, state, local or tribal governments), frequenc y of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden ty pe: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agen cies should not conduct special survey s 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

widel y because o f differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, 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 the ROCI S IC Burden Anal ys is Table. (The table should at minimum include Respondent ty pes, IC activity , Respondent and Responses, Hours/Response, and Total Hours) 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 s hould not be included here. Instead, this cost should be included in Item 14.
The estimated burden hours for this collection of information are 1100 hours. We estimate approximately 30 respondents , including those who respond under the second review process . In order to reach this current 1100 total burden estimate, we reviewed the previous estimate when this application was last active, and factored in several changes resulting from the new regulations including a formal second review process for un successful applicants that fall within an established “ funding band

. ” We estimate that approximately 10 applications will score within the funding band, resulting in 10 additional burden hours from the previous applications ( 10 applications received x 2 h ours) = 20 hours. Estimated number of respondents under the first review 30 Estimated preparation t ime under the first review 3 6 hours Estimated burden hours under the first review 1080 hours Estimated number of respondents under the second review 10 Estimated preparation time under the second review 2 hours Estimated burden hours under the second review 20 hours 1 1006 Affected Public (Estimated Burden Hours): Institutions of higher educatio n 30 respondent s x 3 6 hours = 10 80 estimated burden hours Affected Public (Estimated Burden Hours) 10 80 hours

(Estimated Burden Hours for Second Review): Institutions of higher education Estimated b urden hours for second review 10 respondents x 2 h ours = 20 hours Affected Public (Estimated Burden Hours for Second Review) 20 hours

Total Affected Public Estimated Burden Hours............... 1 100 Average burden hours per respondent (1100 total hours/30 respondents = 36.666)

Estimated Cost to Respondents for Regular Submission Professionals: 30 personnel x 3 6 hours x $30 per hour = $ 3 2 , 4 00 Overhead at 50% of salary=$ 16,200 $ 48,600
Total estimated staff costs to respondents $ 48,600
(a) One time cost to applicant: Use of computer equipment to search for data and generate application in required format. Computer time is $200 and Printing is $10.00 ( 30 applicants x $210) $ 6, 3 00 **(**b) Operation Cost Annual cost to applicant to find and maintain application materials is $100. (30 applicants x $100) $ 3,000 Total estimated annual costs to respondents $ 9,3007

**Total Annual Costs to Respondents: $ 57,900**  (Staff Costs: $ 48,600 + Annual Costs for responding : $ 9 , 3 00 )
Estimated Cost to Respondents for Second Review/Appeals Submission Professionals: 10 personnel x 2 hour s x $30 per hour total = $ 6 00 Total estimated staff costs to respondents for Appeals $ 600 (a) One time cost to applicant: Use of computer equipment to search for data and generate appeal in required format. Computer time is $200 and printing is $10 ( 10 applicants x $210) $ 2 , 100
(b) Operation Cost Annual cost to applicant to compile mat erials for appealing is $100. ( 10 applicants x $100) $ 1 , 000 Total estimated annual cost to respondents for A ppeals. $ 3 , 100

**Total Annual Costs to Respondents for Appeals: $**  **3 ,**  **700** (Staff Costs: $ 60 0 + Annual Costs for Responding : $3 , 100) 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 an y 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. In clude descriptions of methods used to estimate major cost factors including s ys tem and technology

acquisition, expected useful life of capital equipme nt, 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 computers and software; monitoring, sampling, drilling and t esting equipment; and acquiring and maintaining record storage facilities. If cost estimates are expected to vary widel y, 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 econom ic or regulatory impact8

anal ys is 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. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 1 2 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : Annual Costs to Respondents (capital/start

- up, and operation and maintenance): The total for the c apital and start

- up cost components for this information collection is zero. This information collection will not require the purchase of any capital equipment nor create an y start up costs. 14. Provide estimates of annualized cost to the Federal governme nt. 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.
Cost to Federal Government: Professional staff to develop clearance package (GS

- 1 4 employee) 160 hrs @$ 55 per hour $ 8,800 Ov erhead cost related to facilities, administration, and other indirect cost plus accrual of leave and fringe benefits @50% salary

. $ 4,400 Other Department staff to review and approve the request GS

- 15 Employee $630 OMB Review 8hrs. X $45.00 per hour=$3 60.00 x 50% overhead=$180.00 $540 Estimated Sub

- total $14,370 **Cost for Federally -**  **supervised review of applications** Outside field reviewers

– 9 readers @ $1,100 each $ 9 , 9 00 Processing applications

– staff (2 staff x 40 hours x $48 per hours=$ 3840 ) (Ov erhead cost: $ 3840 x 50 percent = $ 1,920 ) $ 5 , 7609

Contractor logistical support for workshop, achieving prior unfunded applications, application processing, field reading and slate preparation ( 4 weeks

- reading) $ 57 , 5 5 2 Staff time for conducting superv ised review. (1 week x 3 control reviews, and 3 panel chairpersons) (6 staff x 40 hours x $48 per hour=$11,520) (Overhead cost: $11,520 x 50 percent=$5,760) $ 17,280 Staff time for generating slate ( 2 staff x $48 per hour x 8 hours=$ 768 ) (Overhead cost : $ 768 x 50 percent = $ 384 ) $ 1,152 Staff time to review and approve funding recommendations ( 5 awards x 4 hours per awards x $48 per hour = $ 960 (Overhead cost: $ 960 x 50 per cent = $ 480 ) $ 1,440 Staff time to generate, approve, and issue grant awards (6 hours per award x 5 awards= 30 hours) ($48 per hr x 30 hours = $ 1440 ) (Overhead cost: $ 1440 x 50 percent = $ 720 ) $ 2 , 160 Total estimate cost to government (competitive year) $ 109,614

15. Explain the reasons for an y program changes or adjustments. Generally , adjustments in burden result from re

- estimating burden and/or from economic phenomenon outside of an agency ’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result f rom a deliberate action that materiall y changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated b y t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for c hanges in burden hours, responses and costs (if applicable). Since this collection is technicall y new, all 1100 hours of burden are considered new burden and represent a program change. The current burden hour estimate is based on 3 0 respondents, including those who respond under the second review process

. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedu le for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. Results of collected information will not be published.10

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. The Department will display on the form the expiration date for the OMB approval as required. 18. Explain each exception to the ce rtification statement identified in the Certification of Paperwork Reduction Act. There are no exceptions to the certification statement.