Supporting Statement for the 

Application for Grants under the

Training Program for 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 necessary. Identify any 

legal or administrative requirements that necessitate the collection. Attach a hard copy 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, briefly specify the changes. If a rulemaking is 

involved, make note of the sections or changed sections, if applicable.

The U.S. Department of Education is requesting a reinstatement without change of a 

previously approved collection to make new grants under the Training (Training) Program. 

The previous collection was discontinued and approval 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 institutions and organizations to support training to enhance the 

skills and expertise of project directors and staff employed in the Federal TRIO Programs. 

Funds may be used for conferences, seminars, internships, workshops, or the publication of 

manuals. Training 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, workshops, and the publication of manuals designed to improve the operation of 

TRIO projects. These trainings are carried out in the various regions to ensure that growth 

opportunities are available to all TRIO personnel in the local projects. The topics covered in 

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 recruiting 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. 

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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 information 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 not 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 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 given to 

using technology to reduce burden. 

For fiscal year 2014, as a part of the Department’s goal to increase the electronic submission 

of applications, applications for grants under the Training program will be submitted 

electronically via the Grants.gov portal. We estimate that the Department will receive 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 specifically why any similar information 

already available cannot be used or modified for use for the purposes described 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 independently 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 

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

reducing burden.

If the collection is not conducted or is collected less frequently, the Department cannot meet 

its grant making responsibilities, 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 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;

 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 that 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 that it has instituted 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 published the 60 and 30 Federal Register notices 

as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to 
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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.

The Department will solicit informal views and comments from persons outside the 

Department during a pre-application workshop for Training as mandated by statute. The 

Department will publish a 30-day Federal Register notice allowing public comment on this 

collection. 

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

of contractors or grantees with meaningful justification.

The Department will not provide any payments or gifts to respondents.

10. Describe any 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. Please 

provide a citation for the Systems of Record Notice and the date a Privacy Impact 

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 provided. If the 

collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with 

respect to confidentiality. If 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 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 application does not include questions about sexual behavior and attitudes, religious 

beliefs, or other items that are commonly considered sensitive and private.
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12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, individuals 

or households, private sector – businesses or other for-profit, private sector – not-for-profit 

institutions, farms, state, local or tribal governments), frequency of response, annual hour 

burden, and an explanation of how the burden was estimated, including identification of 

burden type: recordkeeping, reporting or third party disclosure. All narrative should be 

included in item 12. 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 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 the ROCIS IC Burden Analysis 

Table. (The table should at minimum include Respondent types, 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 should 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 unsuccessful 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 hours) = 20 hours. 

Estimated number of respondents under the first review 30

Estimated preparation time under the first review 36 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

1100
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Affected Public

(Estimated Burden Hours):

Institutions of higher education 30 respondents x 36 hours = 1080

estimated burden hours

Affected Public (Estimated 

Burden Hours)

1080 hours

(Estimated Burden Hours for Second Review):

Institutions of higher education Estimated burden hours for second review 

10 respondents x 2 hours = 20 hours

Affected Public (Estimated 

Burden Hours for Second 

Review)

20 hours

Total Affected Public Estimated Burden Hours...............1100

Average burden hours per respondent (1100 total hours/30 respondents = 36.666)

Estimated Cost to Respondents for Regular Submission

Professionals:

30 personnel x 36 hours x $30 per hour = $32,400

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) $6,300

(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 $9,300
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Total Annual Costs to Respondents: $57,900

(Staff Costs: $48,600 + Annual Costs for responding: $9,300)

Estimated Cost to Respondents for Second Review/Appeals Submission

Professionals:

10 personnel x 2 hours x $30 per hour total = $600

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 materials for appealing is $100. (10

applicants x $100)

$1,000

Total estimated annual cost to respondents for Appeals. $3,100

Total Annual Costs to Respondents for Appeals: $3,700

(Staff Costs: $600 + 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 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 computers and 

software; monitoring, sampling, drilling and testing equipment; and acquiring and 

maintaining 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 preOMB submission public comment process and use existing economic or regulatory impact 
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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. Also, these estimates should not include the hourly costs (i.e., 

the monetization of the hours) captured above in Item 12

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 capital 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 any 

start up costs.

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.

Cost to Federal Government: 

Professional staff to develop clearance package (GS-14 employee) 160 

hrs @$55 per hour $8,800

Overhead 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=$360.00 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 $9,900

Processing applications – staff

(2 staff x 40 hours x $48 per hours=$3840)

(Overhead cost: $3840 x 50 percent = $1,920) $5,760
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Contractor logistical support for workshop, achieving prior unfunded 

applications, application processing, field reading and slate preparation 

(4 weeks-reading) $57,552

Staff time for conducting supervised 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 any 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 from a deliberate action that materially 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 by type of change (i.e., adjustment, program change due to 

new statute, and/or program change due to agency discretion), type of collection (new, 

revision, extension, reinstatement with change, reinstatement without change) and include 

totals for changes in burden hours, responses and costs (if applicable).

Since this collection is technically new, all 1100 hours of burden are considered new burden 

and represent a program change. The current burden hour estimate is based on 30

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 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.

Results of collected information will not be published.
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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 certification statement identified in the Certification of 

Paperwork Reduction Act.

There are no exceptions to the certification statement.