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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

TEACH Grant Data Collection Tool

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 section1. 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.

Section 420P of the Higher Education Act, as amended by the Higher Education 

Opportunity Act of 2008, requires the Secretary of Education to submit a report to 

Congress every two years with respect to schools and students served by schools that 

participate in the Teacher Education Assistance for Higher Education (TEACH) Grant 

Program. The report must take into consideration information related to: (1) the number 

of TEACH grant recipients; (2) the degrees obtained by such recipients; (3) the location,

including the school, local educational agency, and State, where the recipients completed 

the service agreed to under section 420N and the subject taught; (4) the duration of such 

service; and (5) any other data necessary to conduct such evaluation. The Department 

has determined that the inclusion of data on a student’s eligible field of study and cost of 

education is necessary to better inform the evaluation.

Elements 1-4 of the report are based on data collected by Federal Student Aid (FSA) 

through the National Student Loan Data System (NSLDS), the Application Processing 

System, and the Common Origination and Disbursement (COD) System. 

Under element 6, data on eligible field of study and cost of education has been 

determined to be additional information necessary to report to the Secretary. These data 

are collected from each school that participates in the TEACH Grant Program using a 

separate data collection tool. It is this separate data collection tool that is the focus of this 

information collection request.

 

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Please limit pasted text to no longer than 3 paragraphs.
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

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 Department uses the information collected to prepare a Congressionally-mandated 

report on TEACH grants with respect to the schools and students served by recipients of 

such grants. The data collected on a student’s eligible field of study and cost of 

education will be combined with data already collected by FSA to compile this report for 

Congress. 

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.

In order to minimize response burden, a data collection tool used to collect a student’s 

eligible field of study and cost of education was developed and placed on the OPE 

website, as approved OMB Control Number 1840-0819, to collect data for TEACH grant 

funds that were dispersed during the 2012-13 award year. The language on that data 

collection tool will be updated in order to collect those same data for TEACH grant funds 

that are dispersed during the 2013-14 award year.

Features of the electronic data collection tool include:

 The Financial Aid Administrator (FAA) of schools where TEACH grants are dispersed 

will access the data collection tool electronically through a secure website, using 

authorized login and password. The link to the data collection tool, login, and password 

will be sent to the FAA via email.

 Once logged into the data tool, the FAA will enter two data points. One data point will 

be the eligible field of study defined by a Classification of Instructional Programs (CIP 

code) which will be limited through the use of drop down menus from which the FAA 

will choose. The other data point, the cost of education, will be a dollar value amount 

for the cost of education for each student who is obtaining a TEACH grant. The system 

will generate an error message indicating the need for correction if anything other than 

numbers are entered for the education costs. 

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.

This information does not duplicate any other information collection effort. No other 

system collects CIP codes and the cost of education specific to the TEACH Grant

program. The information is not available in other forms or as the result of other 
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

information collections. 

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.

Small businesses or other small entities are not part of the target population of the 

information collection. 

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.

Section 420P of the HEA requires this data collection. The Secretary — and the states 

and institutions required to report — would be out of compliance with the law if the 

information were not collected and reported 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 
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

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.

There are no special circumstances that would require this information collection to be 

conducted in any of the ways listed as part of this question.

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 

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 of Education is seeking the applicable 60 and 30 day notices requesting 

public comment. 

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

of contractors or grantees with meaningful justification.

No payment or gift will be provided to respondents in connection with this data 

collection.

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 
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

authorizes the pledge of confidentiality should be provided.2If 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.

No assurances of confidentiality are provided. A link to the U.S. Department of 

Education’s Privacy Policy is provided on the log in page of the data collection tool 

(http://www2.ed.gov/notices/privacy/index.html).

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.

The data collection includes no questions of a sensitive nature. 

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)

 

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

 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.

This is a reporting requirement. The time required to complete this information 

collection is estimated to average 1 hour per institutional response, including the time to 

review instructions, search existing data sources, gather data needed, and complete and 

review the information collection. In total, 796 institutions will be contacted in regards to 

this data collection. This is a one-time collection and will not be repeated by OPE.

796 Institutions X 1 hour per institution = 796 Total Burden Hours for collection

# of Respondents # of Responses Hours/Response Burden Hours

Proprietary Institutions

438 438 1 hour 438

Not-for-Profit Institutions

11 11 1 hour 11

Public

346 346 1 hour 346

Total 796 796 796

Current Burden

488 488 488

Increase in Burden

308 308 308

As there are only two fields of data that the institutions already collect and a limited 

number of TEACH grant recipients at each institution, we do not feel there will be a cost 

burden associated with the collection.

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 
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

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 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. 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 : 

There are no start-up costs for respondents.

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.

The annualized cost to the Federal government will be approximately $80,398. This 

amount was calculated based on the number of hours it would take to collect and 

aggregate data collected through the system.

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., 
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EDICS Tracking and OMB Number: (XXXX) 1840-0819 Revised: 1/27/2014

RIN Number: XXXX-XXXX (if applicable)

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).

We are requesting an extension to continue this collection of data. The burden of 796 

total hours for 796 institutions is a revision to the current burden. This is an increase of 

308 hours resulting from additional institutions having to report data to meet the 

legislative requirement in section 420P of the Higher Education Opportunity Act. 

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.

The Secretary of Education must submit a report to the Congress. That report will be 

based on data collected by Federal Student Aid (FSA) through the National Student Loan 

Data System (NSLDS), the Application Processing System, and the Common Origination 

and Disbursement (COD) System. The data collected by the Office of Postsecondary

Education from each school that participates in the TEACH Grant Program will be 

included in the report to Congress.

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 do not seek this approval. 

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

Paperwork Reduction Act.

There are no exceptions to the statement, "Certification for Paperwork Reduction Act 

Submissions" of OMB Form 83-1.