1

SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

OMB No. 1810-0683

MIGRANT EDUCATION PROGRAM (MEP) 

PROPOSED REGULATIONS TO IMPLEMENT AND SUPPORT THE MIGRANT 

STUDENT INFORMATION EXCHANGE (MSIX) & MINIMUM DATA ELEMENTS

A. Justification

Q1. 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.

A1. The U.S. Department of Education (ED) is proposing new regulations to implement the Migrant 

Student Information Exchange (MSIX), a nationwide, electronic records exchange mechanism mandated 

under Title I, Part C of the Elementary and Secondary Education Act (ESEA), as amended by the No 

Child left Behind Act. As a condition of receiving a grant of funds under the Migrant Education Program 

(MEP), each State educational agency (SEA) would be required to collect, maintain, and submit 

minimum health and education-related data to MSIX within established timeframes. The proposed 

regulations would facilitate timely school enrollment, placement, and accrual of secondary course credits 

for migratory children and help us determine accurate migratory child counts and meet other MEP 

reporting requirements. The MEP is authorized under sections 1301-1309 in Title I, Part C of the ESEA. 

MSIX and the minimum data elements (MDEs) are authorized specifically under section 1308(b) of the 

ESEA. 

This collection replaces the current collection for the MSIX MDEs under OMB No. 1810-0683. The 

burden hours and costs associated with this data collection are required to ensure that States implement 

and utilize MSIX for interstate migrant student records exchange, which will then enable the Department 

to meet the statutory mandate in section 1308(b) of the ESEA to facilitate the electronic exchange of 

MDEs by SEAs to address the educational and related needs of migratory children.

The information collection addresses the following statutory requirements in the ESEA:

 Section 1304(b)(3), which requires SEAs to promote interstate and intrastate coordination of 

services for migratory children, including providing educational continuity through the timely 

transfer of pertinent school records (including health information) when children move from one 

school to another, whether or not the move occurs during the regular school year.

 Section 1308(b)(1), which requires ED to assist SEAs in providing for the electronic transfer of 

migrant student records.

 Section 1308(b)(2), which requires ED, in consultation with SEAs, to ensure the linkage of 

migrant student record systems for the purpose of electronically exchanging health and 

educational information regarding migrant children among States and determine the MDEs that 

each SEA shall collect and maintain for electronic exchange. 

 Section 1309(2), which provides the statutory definition of a migratory child. A total of 418,643 

migratory children ages 0-21 are eligible for MEP services as reported by the States in their 2010-

11 Comprehensive State Performance Reports (CSPRs). 
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A copy of the relevant sections of Title I, Part C of the ESEA is available in the Applicable Statute 

document. 

In accordance with ESEA section 1308(b)(1), ED’s Office of Migrant Education (OME) awarded a 

contract on September 30, 2006, to provide software design, development, implementation and 

maintenance for MSIX. ED supported two pilot implementations during fiscal year 2007, and the system 

was completed in late September 2007. OME awarded a subsequent contract on July 31, 2011, for the 

continued operations, maintenance, and enhancement of MSIX. MSIX currently contains data for 49

States and 99% of the migrant student population. 

MSIX provides the technology that allows all States to share educational and health information on 

migrant children who travel from State to State and who, as a result, have student records in multiple 

States' information systems. MSIX works in concert with the existing migrant student information 

systems that States currently use to manage their migrant data to fulfill their responsibilities under ESEA 

section 1304(b)(3) to ensure the appropriate enrollment, placement, and accrual of credits for migrant 

children nationwide.

ED has consulted with SEAs since 2002 to identify an appropriate set of MDEs needed to fulfill the 

statutory requirements for records exchange. This process has resulted in a set of 72 defined total MDEs 

that can be retrieved electronically among all States, relying to the maximum extent practicable on 

existing SEA information systems as the source of data that can be exchanged nationally. A document 

with descriptions for the MDEs is available in the Minimum Data Elements.

In order to meet the requirements of ESEA section 1304(b)(3), SEAs participating in the MEP must 

request the records of eligible migrant children who arrive in their State or district and must transmit 

records in a timely manner for those migrant children who move out of their State or district to another 

location. To date, 49 States have provided MSIX with varying amounts of data on their migrant students. 

This information collection includes the burden for the States to complete their start-up data submissions, 

as well as the three-year annualized burden for subsequent data submissions as required under the

proposed regulations.

Q2. 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.

A2. The information to be collected and maintained in MSIX is about individual migrant children aged 0-

21 who are eligible to receive services under the MEP. It will be used by SEAs, migrant student 

educators, MEP personnel, school registrars, and school guidance counselors to retrieve consolidated 

educational and health information among all States on migrant children who move across district and 

State boundaries because of their migrant lifestyle. These MDE’s reflect the minimal information needed 

to ensure proper enrollment, grade and course placement, and accrual of secondary course credits for 

migratory children. ED may also use MDEs to produce child counts and other national data on the 

migrant population. 

The information collection will be conducted by SEAs who will collect, enter, and submit MDEs 

electronically to MSIX from their existing State data systems. In addition to the burden of collecting and 

entering the data into the State’s own data systems, this information collection request also includes the 

burden estimate for SEAs to develop an appropriate interface for submitting all 72 total MDEs to MSIX 

in an electronic format.

MSIX has been operational since 2007 and, as such, many SEAs are already submitting many or all of the 

MDEs for their States’ migratory children. Under the proposed regulations, SEAs are not required to 

resubmit any MDEs to MSIX that have already been submitted. In addition, this information collection is 

needed for only 41 of the MDEs because the other 30 MDEs are collected and entered into State data 
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systems through other sources, including the separately-approved information collections for the MEP 

Certificate of Eligibility (COE) and related regulations, and another collection for ED’s Education Data 

Exchange Network (EDEN). The MDEs also include common business information from State or 

District computer systems, such as the School Identifier Code assigned by the State or District computer 

system. As discussed in A12 below, there is no need to account for the burden of submitting these MDEs 

electronically to MSIX because we have assumed for purposes of this collection that data submission

occurs automatically once the State’s electronic interface with MSIX has been established. 

Information reporting by SEAs will be required as follows: 

Reporting Activity Description Timeframe

1. Start-up Data

Submission -

200.85(b)(2)(i)

Collect and submit to MSIX MDEs 

(applicable to child’s age and grade level) 

for every migrant child whom the SEA 

considered eligible for MEP services within 

one year preceding the effective date of 

the regulations.

No later than 90 calendar 

days after the effective date 

of these regulations 

2. Newly Documented 

Migratory Children

200.85(b)(3)(i)(A)

Collect and submit to MSIX all MDEs 

(applicable to child’s age and grade level) 

for newly documented migrant students.

Within 10 working days of 

documenting the child’s 

eligibility for the MEP

3. Newly Documented 

Migratory Children with 

Secondary School 

Records in the Same 

State -

200.85(b)(3)(i)(B)

Collect and submit all applicable MDEs 

from the most recent secondary school 

previously attended by the student within 

the same State 

Within 10 working days of 

documenting the child’s 

eligibility for the MEP

4.* Newly Documented 

Migratory Children with 

Secondary School 

Records from Another 

State -

200.85(b)(3)(i)(B)

Notify MSIX if one of its local operating 

agencies obtains records from a secondary 

school previously attended by the migrant 

student in another State.

Within 30 calendar days of 

receipt of records by an LEA.

5. End of Term 

Submission -

200.85(b)(3)(ii) 

Collect and submit to MSIX all MDE 

updates and newly available MDEs for 

migratory children who were eligible for the 

MEP during the term and for whom the 

SEA previously submitted data

Within 30 calendar days of 

the end of an LEA or local 

operating agency’s fall, 

spring, summer, or 

intersession terms

6. Change of Residence 

Submission -

200.85(b)(3)(iii)

Collect and submit to MSIX all newly

available MDEs and MDE updates that 

have become available to the SEA or one 

of its local operating agencies.

Within 4 working days of 

receiving notification from 

MSIX that migratory child has 

changed residence to a new

local operating agency within 

the State or to a new State

7. Parental Request for 

MSIX Data Correction -

200.85(e)(1)(ii)

If an SEA determines that data previously 

submitted to MSIX should be corrected as 

the result of a request from a parent, 

guardian, or migrant student, the SEA shall 

submit revised data to MSIX to correct the 

previously submitted data

Within 4 working days of the 

SEA’s determination to 

correct the data previously 

submitted to MSIX

8. Response to ED -

200.85(e)(3)

Submit information requested by ED 

needed to respond to an individual’s 

request to amend a record under the 

Privacy Act.

Within 10 working days of 

ED’s request.

*This data element is the only new MDE being added to this collection. All other MDEs were previously 

approved under OMB No. 1810-0683.

This information collection is used to enable MSIX to enhance the continuity of services for migrant 
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children by providing a mechanism for SEAs to exchange educational and health related information on 

migrant children who move from one State or district to another. Pursuant to section 1308 of the ESEA, 

the information will enable SEAs to exchange MDEs that have been identified as necessary for fulfilling 

the requirements of the MEP for continuity of instruction. It is anticipated that the information made 

available through this collection will enable SEAs to reduce educational disruptions for migrant children, 

provide information needed for school placements, ensure academic credit for school work completed, 

streamline academic progression toward graduation requirements, and provide complete academic records 

needed for postsecondary education and employment opportunities. It is also anticipated that the 

existence and use of MSIX will help to reduce incidences of unnecessary immunizations of migrant 

children because of a lack of timely, accurate health information, and facilitate the timely accrual of 

credits for secondary school migrant students by providing accurate academic information on the 

student’s courses and academic progress.

Q3. 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.

A3. The information collection requires SEAs to submit MDEs as electronic information to MSIX. 

SEAs are already using automated information systems to collect, analyze and maintain information on 

migrant children, and to the extent consistent with digital information exchange requirements, SEAs may 

continue to use existing automated systems for collecting and submitting MDEs to MSIX. Additionally, 

49 SEAs are already electronically submitting some or all of the MDEs to MSIX. It is assumed that once 

an electronic interface has been established between State information systems and MSIX, there is no 

additional effort to electronically submit data to MSIX that has already been collected and entered into the 

State information systems.

Q4. 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.

A4. The information that SEAs submit to MSIX is unique to each child enrolled in the MEP and, while 

some of the data are collected and available directly from the States, they are not all collected or available 

for interstate information exchange on a national basis (and in a cross-State consolidated student file)

through any source other than MSIX. As noted in A2 above, States already collect and enter into their 

data bases some of the MDEs under separate ED information collections. This MSIX information 

collection will not duplicate (or otherwise include) the burden associated with the MDEs available for 

submission to MSIX from other authorized collections, including the COE and EDEN information 

collections. That is, those data collection burdens are not included in this supporting statement even 

though the submission of those MDEs to MSIX is mandatory under the proposed regulations because the 

burdens for collecting and entering these data into State systems have been accounted for elsewhere.

Q5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB 

Form 83-I), describe any methods used to minimize burden.

A5. Small businesses are not impacted by this data collection.

Q6. 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.

A6. If the collection is not conducted, ED will be unable to carry out its statutory mandate under section

1308 of the ESEA. Additionally, SEA grantees of the MEP would be hindered in determining the 

educational and health status of migratory children who move among States, making prompt and 

appropriate educational placements, and providing for a continuity of services for migrant children. In 

addition, migrant children may be at risk of omitted or unnecessary immunizations. Secondary students 
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may be unable to document coursework that could be important for graduation, entry into postsecondary 

education, or employment opportunities. 

Q7. Explain any special circumstance 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-inaid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and reliable results that 

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 that it has instituted procedures to protect the information's confidentiality to 

the extent permitted by law.

A7. Moves by migratory children throughout the school year provide special circumstances for expedited 

data collection and submission to MSIX. Section 1308(b)(2)(B) of the ESEA provides that SEAs shall be 

able to obtain “immediate access” to the required MDEs. ED and its contractors have determined, after 

consultation with intended users among the State and local MEP staff, that this statutory provision can 

best be achieved by requiring an SEA to submit applicable MDEs to MSIX within 10 working days of 

documenting that a child is eligible for the MEP, and within 4 working days of notice from MSIX of a 

child’s change in residence. It is anticipated that all other information collection requirements will 

conform to 5 CFR § 1320.5, including the requirement for SEAs to provide updated and newly available

information about children within 30 calendar days of the end of each semester, trimester, intersession, or 

summer session.

Respondents should retain records for as long as a migrant child is in the MEP program, which may be 

for more than three years. Records must be available to SEAs to ensure proper enrollment, grade and 

course placement, and accrual of secondary course credits for migratory children

Consultation with the States revealed that not all States were ready to submit all of the MDEs when 

MSIX first became operational and instead submitted MDEs in the following three phases to minimize 

the submission burden: Phase 1- basic student information and demographics; Phase 2- assessment 

information; and Phase 3- course history information. Phased implementation of MSIX is no longer 

warranted as States have largely included the required MDEs in their statewide or migrant-specific

databases. Under the proposed regulations, SEAs that have not already done so are required to provide all 

of the 72 total MDEs in their first submission within 90 days of the effective date of the regulations, and 

then to provide subsequent information as discussed in the preceding paragraphs.

Q8. 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.
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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.

A8. The Department published a 60-day data collection notice with the cited NPRM in the Federal 

Register. 

Q9. Explain any decision to provide any payment or gift to respondents, other than remuneration of 

contractors or grantees.

A9. No gifts or payments to be made to respondents. 

Q10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance 

in statute, regulations, or agency policy.

A10. Although this collection does not provide any assurance of confidentiality, all persons who access 

this information must accept and sign the MSIX Rules of Behavior, which contain a detailed description 

of the safeguards that each system user must follow to protect the privacy and security of the information. 

The Rules of Behavior requires compliance with the confidentiality standards in the Privacy Act of 1974 

as amended. A Privacy Impact Assessment is published online. The Department published a System of 

Records Notice for MSIX in the Federal Register on December 5, 2007, Vol. 72, number 233, pages 

68572-68576. The SORN is currently being updated for non-substantive revisions.

Q11. 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. This 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.

A11. The proposed regulations do not require any questions of sensitive nature in this collection of 

information.

Q12. 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 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 13 of OMB Form 83-I.

 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.
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A12. Estimated hour burden for the collection of information. 

Amortized over three years, the total annualized burden for all SEA respondents is estimated at 465,866

hours for all information collection requirements in the proposed regulations. This amounts to an average 

of 9,317 hours per year for each of the 50 participating SEAs (including three States administered under

the MEP bypass arrangement). Because eligibility for MEP services varies greatly among the States, we 

have also estimated the overall burden as 1,113 hours annually per 1,000 eligible children as a means for 

enabling individual SEAs to assess the impact of the information collection burden.

These estimates were developed in consultation with the States by program and contract staff with 

experience in the State-level administration of the MEP. See the tabular summaries and discussion below 

for a further explanation of the calculations.

Estimates of Annualized Burden to SEA Respondents:

As noted in A2 above, these estimates include the burden for only 41 of the 72 total MDEs covered under 

this information collection. The remaining MDEs are collected under separately approved information 

collections, including collections for the MEP Certificate of Eligibility (COE) and EDEN. We estimated 

the burden in minutes by reporting activity based upon consultation with States, analysis of the 

information reported by each State in its 2010-2011 CSPR, and State data submitted previously to MSIX. 

The estimated burden to collect the MDE information includes the effort to enter the data in the 

appropriate State information systems for electronic transmission to MSIX. It is assumed that this 

activity would be integrated into each State’s ongoing processes for routine MEP student information 

collection and data processing. It is also assumed that once the one-time activity to implement an 

electronic interface between the State information system(s) and MSIX has been completed, there is no 

additional measurable effort for the electronic submission of collected data to MSIX.

By Reporting Ativity

Annualized Burden for 

all SEA Respondents

1 Start-up Data Submissions 21,651 

2 Newly Documented Migratory Children 109,435 

3 Newly Documented (Secondary Records - Same State) 26,664 

4 Newly Documented (Secondary Records - Out of State) 15,609 

5 End of Term Submissions 291,278 

6 Change of Residence Submissions 1,194 

7 Parental Request to SEA for Data Correction 31 

8 Response to ED - Parental Request to ED for Data Correction 4 

Annualized Total over 3 Years for All SEAs 465,866 

Average Hours per SEA 9,317 

Average Person Years per SEA (at 2,080 hours/year) 4.5 

Average Hours per 1,000 Eligible Children (of 418,643 Children) 1,113 

Start-up Data Submissions. Twenty-two States have already met the requirement to collect and submit 

to MSIX MDEs for every migrant child considered eligible in the State within the preceding year; the 

remaining 28 States have met the requirement to varying degrees. Amortized over three years, the 

annualized burden of the requirement for the remaining 28 States is estimated to be 21,651 hours per year

in total and 773 hours per year per SEA. Start-up Data Submission is a one-time requirement for each 

SEA. All subsequent data submission requirements are covered by the other information collection 

activities described below.
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Newly Documented Migratory Children. Amortized over three years, the annualized burden of the 

requirement for 50 States to collect and submit the MSIX MDEs within 10 days of documenting the 

eligibility of each new migratory child is estimated at 109,435 hours per year in total and 2,189 hours per 

SEA. Documenting the eligibility of migratory children is an ongoing process, and the burden remains at 

a constant level in each of the three years.

Newly Documented Migratory Children with Prior Secondary School Records in the Same State. 

The annualized burden of the requirement for States to collect and submit to MSIX MDEs from the most 

recent secondary school attended previously within the State is estimated 26,664 hours per year in total 

and 533 hours per year for each SEA. Collecting and submitting secondary school information for newly 

documented migratory children is an ongoing process, and the burden remains at a constant level in each 

of the three years.

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Once per SEA 28 SEAs 2,239 62,691 This estimate includes time to

collect MSIX MDE inforation that has

not already been collected for each 

student considered eligible by the 

SEA in the preceding year

Data 

Submission

Once per SEA 28 SEAs 81 2,261 This estimate includes time for 

SEAs to complete development and 

implementation of their MSIX

interface to enable the exchange of

all MSIX MDEs

Total over 3 Years 2,320 64,952

Person Years (at 2,080 hours/year) 1.1 31

Annualized Average 773 21,651 28 SEAs to complete interface work

Person Years (at 2,080 hours/year) 0.4 10 28 SEAs to complete interface work

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 10 

days of

documenting 

a child's 

eligibility

50 SEAs 6,566 328,304 This estimate includes time to

collect MSIX MDE information for 

each newly documented migrant

student and enter it into the State's

MEP system

Data 

Submission

Within 10 

days of

documenting 

a child's 

eligibility

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the collected MDEs to MSIX

Total over 3 Years 6,566 328,304

Person Years (at 2,080 hours/year) 3.2 158

Annualized Average 2,189 109,435

Person Years (at 2,080 hours/year) 1.1 53
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Newly Documented Migratory Children with Secondary School Records from Another State. The 

annualized burden of the requirement for States to notify MSIX within 30 days of obtaining out-of-state 

secondary school records for a newly documented migratory child is estimated at 15,609 hours per year in 

total and 312 hours per year for each SEA. This burden estimate also includes a one-time effort for each 

State to modify its State data system and MSIX interface to collect and submit a new MDE to indicate 

whether or not out-of-state school records are present at an LEA for a migrant student. Documenting 

migratory children is an ongoing process, and the burden remains at a constant level in each of the three 

years. 

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 10 

days of

documenting 

a child's 

eligibility

50 SEAs 1,600 79,992 This estimate includes time to

collect Course History MDE

inforation for the most recent

secondary school attended 

previously in the state by migrant

student and enter it into the State's

MEP system

Data 

Submission

Within 10 

days of

documenting 

a child's 

eligibility

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the collected MDEs to MSIX

Total over 3 Years 1,600 79,992

Person Years (at 2,080 hours/year) 0.8 38

Annualized Average 533 26,664

Person Years (at 2,080 hours/year) 0.3 13

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 10 

days of

documenting 

a child's 

eligibility

50 SEAs 901 45,028 This estimate includes time to

whether or not an LEA in the State

has records from another State for a 

migrant student and enter indicate it

in the State's MEP system

Data 

Submission

Once per SEA 50 SEAs 36 1,800 This estimate includes for each SEA

to modify their State MEP system 

and MSIX interface to collect and 

submit a new MDE to indicate 

whether or not Out-of-State school 

records are present at an LEA for a

migrant student.

Data 

Submission

Within 10 

days of

documenting 

a child's 

eligibility

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the collected MDEs to MSIX

Total over 3 Years 937 46,828

Person Years (at 2,080 hours/year) 0.5 23

Annualized Average 312 15,609

Person Years (at 2,080 hours/year) 0.2 8
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End of Term Submissions. The annualized burden of the requirement to collect and submit updated and 

newly available MDEs to MSIX within 30 days after the end of each educational term for all eligible 

MEP children is estimated at 291,278 hours per year in total and 5,826 hours per year per SEA. This is an 

ongoing process, and the burden remains at a constant level in each of the three years. 

Notice of Change of Residence Submissions. The annualized burden of the requirement to collect and 

submit to MSIX all new and updated MDEs within four days of receiving notification from MSIX that a 

migratory child has changed residence is estimated at 1,194 hours per year in total and 24 hours per year 

per SEA. This is an ongoing process, and the burden remains at a constant level in each of the three 

years.

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 30 

days of the 

end of a term

50 SEAs 17,477 873,834 This estimate includes time to

collect newly available MDE 

inforation for each eligible migrant

student in the State and enter it into 

the State's MEP system

Data 

Submission

Within 30 

days of the 

end of a term

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the collected MDEs to MSIX

Total over 3 Years 17,477 873,834

Person Years (at 2,080 hours/year) 8.4 420

Annualized Average 5,826 291,278

Person Years (at 2,080 hours/year) 2.8 140

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 4 days 

of receiving 

notification 

from MSIX that

a migratory

child has

changed 

residence

50 SEAs 72 3,583 This estimate includes time to

collect new MDE inforation that has

become available for migrant

student since the last submission to

MSIX and enter it into the State's

MEP system

Data 

Submission

Within 4 days 

of receiving 

notification 

from MSIX that

a migratory

child has

changed 

residence

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the collected MDEs to MSIX

Total over 3 Years 72 3,583

Person Years (at 2,080 hours/year) 0.0 2

Annualized Average 24 1,194

Person Years (at 2,080 hours/year) 0.0 1
11

Parental Request to SEAs for MSIX Data Correction. The annualized burden for SEAs to submit 

revised data to MSIX within four working days of the decision to correct previously submitted data 

following a request from a parent, guardian, or student is estimated at 31 hours per year in total and .06 

hours per year per SEA. This is an ongoing process, and the burden remains at a constant level in each of 

the three years.

Parental Request to ED for MSIX Data Correction. The annualized burden for SEAs to respond 

within ten working days to request from ED for information needed by ED to respond to an individual’s 

request to correct or amend a Consolidated MSIX Record under the federal Privacy Act is estimated at 

four hours per year in total and 0.1 hour per year per SEA. This is an ongoing process, and the burden 

remains at a constant level in each of the three years.

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 4 days 

of

determination 

to correct data 

submitted to

MSIX

50 SEAs 1.9 94 This estimate includes effort to

correct information previously

entered in the State's MEP system

Data 

Submission

Within 4 days 

of

determination 

to correct data 

submitted to

MSIX

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the corrected data to MSIX

Total over 3 Years 1.9 94

Person Years (at 2,080 hours/year) 0.0 0

Annualized Average 0.6 31

Person Years (at 2,080 hours/year) 0.0 0

Activity

Frequency of

Response

Number of

Respondents

Average 

Hours per 

Respondent

Total Hours 

over 3 Years Description

Data 

Collection

Within 10 

days of a

request for 

information 

from the 

Department

50 SEAs 0.2 11 This estimate includes effort to

respond to a request from the 

Department to correct or amend 

data previously entered in the State 

MEP system and submitted to MSIX

Data 

Submission

Within 10 

days of a

request for 

information 

from the 

Department

50 SEAs - - It is estimated that there is no 

additional effort to electronically

submit the corrected data to MSIX

Total over 3 Years 0.2 11

Person Years (at 2,080 hours/year) 0.0 0

Annualized Average 0.1 4

Person Years (at 2,080 hours/year) 0.0 0
12

Our calculations are based on 2,080 hours (or 260 days) per person year. Additional information about 

the basis of the burden estimates is available in a supplementary document, Minimum Data Elements,

which lists all 72 total MDEs and identifies the 41 that will require data collection and submission under 

this information collection. 

Estimates of Annualized Cost to SEA Respondents:

Amortized over three years, the estimated overall annualized cost nationally is $15,382,888. The total 

average annualized cost per respondent for all reporting activities is $318,892. The calculations use an 

average cost of $33.02

1

an hour for all SEA respondents involved in information collection and 

submission. Using the break-down of hours presented above, the estimated costs in dollars are as follows:

1. Start-up Data Submission

2. Newly Documented Migratory Children

 

1 The mean hourly earnings value for State and Local Government management, professional, and related 

occupations of $33.02 is based on U.S. Bureau of Labor Statistics National Compensation Survey: Occupational 

Earnings in the United States, 2010. 

Annualized 

Burden for All 

Respondents

Annualized Cost 

Nationally

@$33.02

Cost per SEA 

@$33.02

1 Start-up Data Submission 21,651 $ 714,901 $ 25,532

2 Newly Documented Migratory Children 109,435 $ 3,613,529 $ 72,271

3 Newly Documented Migratory Children (Secondary Students) 26,664 $ 880,440 $ 17,609

4 Newly Documented Migratory Children (Out of State Records) 15,609 $ 515,420 $ 10,308

5 End of Term Submission 291,278 $ 9,618,004 $ 192,360

6 Change of Residence Submission 1,194 $ 39,438 $ 789

7 MSIX Data Correction 31 $ 1,032 $ 21

8 Response to the Department 4 $ 124 $ 2

Annualized Total for all SEAs 465,866 $ 15,382,888 $ 318,892

Average per 1,000 Eligible Children (of 418,643 children) 1,113 $ 36,744.64

By Reporting Ativity

` Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 62,691 30.1 $ 2,070,044 2,239 1.1 $ 73,930 

Data 

Submission

 2,261 1.1 $ 74,658 81 0.0 $ 2,666 

Totals 64,952 31 $ 2,144,702 2,320 1.1 $ 76,596

Annualized Avg. 21,651 10 $ 714,901 773 0.4 $ 25,532

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 328,304 158 $ 10,840,586 6,566 3.2 $ 216,812 

Data 

Submission

 - - $ - - - $ - 

Totals 328,304 158 $10,840,586 6,566 3.2 $ 216,812

Annualized Avg. 109,435 53 $ 3,613,529 2,189 1.1 $ 72,271
13

3. Newly Documented Migratory Children with Previous Secondary Records in Same State

4. Newly Documented Migratory Children with Secondary Records from Another State

5. End of Term Submissions

6. Change of Residence Submission

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 79,992 38 $ 2,641,320 1,600 0.8 $ 52,826 

Data 

Submission

 - - $ - - - $ - 

Totals 79,992 38 $ 2,641,320 1,600 0.8 $ 52,826

Annualized Avg. 26,664 13 $ 880,440 533 0.3 $ 17,609

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 45,028 22 $ 1,486,825 901 0.4 $ 29,736 

Data 

Submission

 1,800 1 $ 59,436 36 0.0 $ 1,189 

Totals 46,828 23 $ 1,546,261 937 0.5 $ 30,925

Annualized Avg. 15,609 8 $ 515,420 312 0.2 $ 10,308

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 873,834 420 $ 28,854,013 17,477 8.4 $ 577,080 

Data 

Submission

 - - $ - - - $ - 

Totals 873,834 420 $28,854,013 17,477 8.4 $ 577,080

Annualized Avg. 291,278 140 $ 9,618,004 5,826 2.8 $ 192,360

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 3,583 2 $ 118,315 72 0.0 $ 2,366 

Data 

Submission

 - - $ - - - $ - 

Totals 3,583 2 $ 118,315 72 0.0 $ 2,366

Annualized Avg. 1,194 1 $ 39,438 24 0.0 $ 789
14

7. Parental Requests to SEAs for MSIX Data Correction

8. Parent Requests to ED for MSIX Data Correction/Response to ED

The costs to respondents are those shown above for staff time for data collection and submission. SEAs 

already collect many of the data elements, and most are already submitting many or all of the MDEs to 

MSIX. There should be no additional record-keeping costs beyond those covered under customary and 

usual business practices. 

Q13. 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 

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.

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 94 0 $ 3,096 1.9 0.0 $ 62 

Data 

Submission

 - - $ - - - $ - 

Totals 94 0 $ 3,096 1.9 0.0 $ 62

Annualized Avg. 31 0 $ 1,032 0.6 0.0 $ 21

Nationally Per SEA

Total Hours 

over 3 Years Person Years

Cost @ 

$33.02 per 

Hour

Total Hours 

over 3 Years Person Years

Cost @

$33.02 per 

Hour

Data

Collection

 11 0 $ 371 0.2 0.0 $ 7

Data 

Submission

 - - $ - - - $ - 

Totals 11 0 $ 371 0.2 0.0 $ 7

Annualized Avg. 4 0 $ 124 0.1 0.0 $ 2
15

A13. The only costs to respondents are those shown above for staff time for data collection and 

submission activities. SEAs already collect many of the data elements, most are already submitting data 

to MSIX, and all have existing information systems in place. There should be no additional recordkeeping costs beyond those covered under customary and usual business practices.

Q14. 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.

A14. Estimated annualized Federal cost:

We estimate the annualized Federal Cost for the requirements of this information collection over the next 

three years to be $2,868,947, calculated as follows:

The cost of the MSIX system includes development funded in Fiscal Year 2006 and implemented in 

Fiscal Year 2007. Funding in Fiscal Years 2007 through 2011 paid for acquisition and maintenance until 

the contract expired on September 29, 2011. A new contract for the continued operation and maintenance 

of MSIX was awarded on August 1, 2011 and expires on July 31, 2016.

The cost of Federal personnel time is estimated at $120,200 per full-time person per year in Fiscal Year 

2007. The Federal personnel cost is based on a GS-13 in an intermediate pay step who works in the 

Washington, DC area, and it is fully loaded with the cost of fringe benefits. The annual cost as been 

escalated at a rate of 3 percent per year as an adjustment for possible cost of living increases to Federal 

pay. Federal personnel cost is extended through Fiscal Year 2015. The average annualized Federal 

personnel cost for 2.2 Full Time Equivalents (FTEs) is $325,323.

The MSIX contractor costs are based on a contract that has been awarded, including the costs of option 

years to continue operating the system. The average annualized contractor cost is $2,543,625.

ED Staff Time in

Government FTEs

ED Staff Costs 

(Loaded with

Benefits, 3% annual 

increase)

MSIX Contract 

Costs Totals

Historical Costs

FY 2006 2.20 $ - $ 7,980,831 $ 7,980,831

FY 2007 2.20 $ 264,440 $ 3,129,097 $ 3,393,537

FY 2008 2.20 $ 272,373 $ 3,262,624 $ 3,534,997

FY 2009 2.20 $ 280,544 $ 3,034,085 $ 3,314,630

FY 2010 2.20 $ 288,961 $ 3,161,144 $ 3,450,105

FY 2011 2.20 $ 297,630 $ 3,632,746 $ 3,930,376

FY 2012 2.20 $ 306,558 $ 2,660,856 $ 2,967,415

Total $ 1,710,506 $ 26,861,385 $ 28,571,892

Annualized Total $ 244,358 $ 3,837,341 $ 4,081,699

Next 3 Years

FY 2013 2.20 $ 315,755 $ 2,702,637 $ 3,018,393

FY 2014 2.20 $ 325,228 $ 2,469,194 $ 2,794,422

FY 2015 2.20 $ 334,985 $ 2,459,042 $ 2,794,027

Total $ 975,968 $ 7,630,874 $ 8,606,842

Annualized Total $ 325,323 $ 2,543,625 $ 2,868,947
16

The overall $2,868,947 annualized cost of MSIX for both Government FTE and contractor costs is the 

average per-year cost, based on a total of $8,606,842 which has been funded in Fiscal Years 2013 through 

2015. 

Q15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB 

Form 83-I.

A15. For this collection, there is an overall increase in the burden from what was reported in the 2011 

update for this collection. There are two factors that contribute to this burden increase. First, the 

previous burden applied to 48 respondents, because Connecticut and Rhode Island were not operating a 

MEP at the time. The Department since awarded a by-pass contract for the operation of MEPs in

Connecticut and Rhode Island which brought the total number of respondents to 50. In July 2013, the bypass contract ended. The data burden for the by-pass states is being included due to the fact that the SEAs 

associated with these states may decide to participate in the MEP in the future. The second factor that 

contributes to the increased burden is the change to the associated reporting activities. The prior version 

of this collection identified three reporting activities. To align with the proposed regulations, the previous 

three activities have been replaced with eight new reporting activities. The new reporting activities more 

clearly identify the collection activities and better align with MEP business practices and MSIX 

functionality.

Q16. 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.

A16. The collection of information does not require publication of the information or use of complex 

analytical techniques. Summary information may be reported by the Secretary in tabular form to the 

States, Congress and the public. 

Q17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

A17. Given that the information collection will be conducted by SEAs with data transmitted 

electronically, the proposed display of the expiration date of OMB approval for the data collection would 

be inappropriate because the collections are being done by SEAs rather than the Federal Government or 

through a Federal contractor. 

Q18. Explain each exception to the certification statement identified in Item 20, "Certification for 

Paperwork Reduction Act Submissions," of OMB Form 83-I.

A18. There are no proposed exceptions to the certifications.

B. Collections of Information Employing Statistical Methods

The data collection does not require that statistical methodology be employed.