### 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 aut horizing 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 e ducational a gency ( SEA ) would be required to collect, m aintain, 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 s ection 1308(b) of the ESEA

. This collection replaces the current collection for the MSIX MDE s under OMB No. 1810

- 0683

. The burden hours and costs associated with th is data collection are required to ensure that S tates implement and utilize MSIX for int erstate migrant student records exchange, which will then enable the Department to meet the statutory man date 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 chi ldren.

The information collection ad dresses 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 co ntinuity 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 mi grant student records.

 Section 1308(b)(2) , which requires ED, in consultation with SEAs, to ensure the linkage of mi grant student record systems for the purpose of electronically exchanging health and educational information regarding mi grant 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 m igratory child. A total of 418,643 mi gratory children ages 0

- 21 are eligible for MEP services as reported by the States in the ir 2010

- 11 Comprehensive State Performance Report s (CSPR s ).

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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 s ection 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 f iscal ye ar 2007, and th e system was completed in late September 2007. OME awarded a subsequent contract on July 31, 2011 , fo r the continued operations, maintenance, and enhancement of MSIX. MSIX currently contains data for 49 States and 9 9 % of the migrant student population. MSIX provides the technology that allows all States to share educational and health information on
m ig rant children who travel from State to State and who, as a result, have student records in multiple S tates' information systems. MSIX works in concert with the existing migrant student information systems that States currently use to manage their mi gran t 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 ne eded 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 syste ms 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 ano ther location . To date, 49 States have provided MSIX with varying amounts of data on their migrant students. This information collection includes t he burden for the States to complete t heir 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 colle ction, indicate the actual use the agency has made of the information received from the current collection.

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

- 21 who are eligible to receive services und er 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 S tate 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 mi gratory children. ED may also use MDEs to produ ce child counts and other national data on the mi grant 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 t he burden of collecting and entering the data into the State’s own data system s , this information collection request also includes the burden estimate for SEAs to develop an appropriat e interface for submitting all 72 total MDEs to MSIX in an electronic fo rmat

. MSIX has been operational since 2007 and, as such, many SEAs are already submitt ing 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. A s 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
occ urs automatically once the State’s electronic interface with MSIX has been established. Information reporting by SEAs will be required as follows:

**Reporting A ctivity**  **Description Timeframe**  1

. Start

- up Data S ubm ission

- 200.85 (b)(2)(i) Collect and s ubm it 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 ye ar preceding the effective date of the regulations. No later than 90 calendar days after the effective dat e of these regulations

2

. Newly Documented Migratory Children 200.85(b)(3)(i)(A) Collec t and submit to MSIX all MDEs (applicable to child’s age and grade level) for newly documented migrant students. Wi thin 1 0 working day s 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 m ost recent secondary school previously attended by the student within the same State Wi thin 10 working days of documenting the child’s eligibility for the MEP

4

. 

### * Newly Documented Migratory Children with Secondary School Records from A nother 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. Wi thin 30 calendar day s of receipt of records by

an LEA

.

5 . End of Term Subm ission

- 200.85(b)(3)(ii) Collect and submit to MSIX all MDE updates and newly

available MDEs for mi gratory

children who were eligible for the MEP during the term and for whom the SEA previously submitted data Wi thin 30 calendar day s of the end of an LEA or local operating agency’s fall, spring, summer, or intersession terms 6 . Change of Residence Su bm ission

- 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

. Wi thin 4 working day s of receiving notification from MSIX that migratory child has changed residence to a new local operating agency within the S tate or to a new S tate 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 Wi thin 4 working day s of the SEA’s determination to correct the data previously submitted to MSIX

8

. Response to ED

- 200.85(e)(3) Subm it information requested by ED needed to respond to an individual’s request to amend a record under the Privacy Act. Wi thin 10 working day s of ED’s r equest

.


### *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 mi grant children who move from one Stat e or district to another. Pursuant to section 1308 of the ESEA, the information will enable SEAs to exchange MDEs t hat have been identified as necessary for fulfilling the requirements of the MEP for continuity of instruction. Itis anticipated that the information made available through this collection will enable SEAs to reduce educational disruptions for migrant ch ildren, 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 employm ent opportunities. Itis also anticipated th at 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
cre dits 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, mecha nical, 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 infor mation 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 mi grant 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 t o MSIX. Itis 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 informa tion 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 i nclude) the b urden associated with the MDEs available for submission to MSIX from other authorized collections , including the COE and EDEN information collections . T hat is, those data collection burdens are not included in this supporting statement even t hough the submissi on of those MDEs to MSIX is mandatory under the proposed regulations because the burdens for col lecting and entering these data into State systems have been accounted for elsewhere

. Q5. If the collection of information impacts small bu sinesses 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 sec tion 1308 of the ESEA. Addi tionally, SEA grantees of the MEP would be hindered in determining the educational and health status of migr atory children who move among States, making prompt and appropriate educational placements, and providing for a continuity of services for migrant c hildren. In addition, migrant children may be at risk of omitte d or unnecessary immunizations. Secondary students

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### ma y 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:

 r equiring 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 o riginal 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 produ ce 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 author ity 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 r espondents 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. M oves by migratory chil dren throughout the school year provide special circumstances for expedited data collection and submission to MSIX

. Sec tion 1308(b)(2)(B) of the ESEA provid es that SEAs shall be able to obtain “immediate access” to the required MDEs. ED and its contra cto rs 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 e ligible for the MEP, and within 4 working days of notice from MSIX of a child’s change in residence

. Itis 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 m ore than three years. R ecords 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 i nformation. P hased implementation of MSIX is no longer warranted as States have largely included the required MDEs in their statewide or mi grant

- specific databases. Under the proposed regulations, SEAs that have not already done so are required to provid e all of the 7 2 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 des cribe 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 c ollection, 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 thos e 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 s hould 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 infor mation. The Rules of Behavior require s 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, 20 07, 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 informa tion 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 informa tion 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.

A mortized over three years, the total annualized burden for all SEA respondents is estimated at 46 5,866 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 (in cluding three States administered under the M EP b ypass 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 b urden in minutes by r eporting activity based upon consultation with States , analysis of the information reported by each State in its 20 10

- 201 1 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 A** 

**tivity An**  **nualized 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 **An nualized Total**  **over 3 Years for A ll SEA** **s 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 77 3 hour s 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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### New **ly Documented Migratory Children**

. Amortized over three years, t he 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.

**New ly 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 s ubmitting 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. **Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Dat a Collec ti on On ce p er S EA 28 SEA

s 2 ,2 39 6 2, 691 Th is e st im at e inc ludes ti me to
co llect M SIX M DE inf or at ion th at

h as not a lr eady b een collec te d fo r e ach st udent c ons idered eligible by th e SEA i n th e pr eceding ye ar Dat a Subm is si on On ce p er S EA 28 SEA

s 8 1 2 ,2 61 Th is e st im at e inc ludes ti me fo r SEA s to co mp let e dev

elopm ent

a nd im plem ent at ion of

th eir MS IX int er fa ce to e nable th e ex

change of all MS IX M DEs To ta l ov er 3 Y ears 2, 320 64, 952 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 1. 1 31 An nualiz ed Ave rage 773 21, 651 28 SEAs to co mp let e int er fa ce w ork Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 4 10 28 SEAs to co mp let e int er fa ce w ork

**Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Dat a Collec ti on Wi th in 10

day s of docum ent ing
a child' s eligibility 50 SEA s 6 ,5 66 3 28, 304 Th is e st im at e inc ludes ti me to
co llect M SIX M DE inf or ma ti on fo r each newly

d oc um ent ed mi grant st udent a nd ent er

i t i nt o th e Sta te 's ME P s ys te m Dat a Subm is si on Wi th in 10

day s of docum ent ing
a child' s eligibility 50 SEA s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e collec te d MD Es to M SI X

To ta l ov er 3 Y ears 6, 566 328, 304 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 3. 2 158 An nualiz ed Ave rage 2, 189 109, 435 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 1. 1 53

### 9



### New **ly Documented Migratory Children with Secondary School Records from Anothe r 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 o ut

- of

- s tate school records are present at an LEA for a migrant student. Documenting mi gratory children is an ongoing process, and the burden remains at a constant level in each of the three years. **Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Dat a Collec ti on Wi th in 10

day s of docum ent ing
a child' s eligibility 50 SEA s 1 ,6 00 7 9, 992 Th is e st im at e inc ludes ti me to
co llect C ours e His to ry

M DE inf or at ion fo r th e mo st

re ce nt
se condary

s ch ool atte nded pr ev ious ly i n th e st at e by

m igrant st udent a nd ent er

i t i nt o th e Sta te 's ME P s ys te m Dat a Subm is si on Wi th in 10

day s of docum ent ing
a child' s eligibility 50 SEA s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e collec te d MD Es to M SI X

To ta l ov er 3 Y ears 1, 600 79, 992 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 8 38 An nualiz ed Ave rage 533 26, 664 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 3 13

**Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Data Collec ti on Wi th in 10

day s of docum ent ing
a child' s eligibility 50 SEA s 9 01 4 5, 028 Th is e st im at e inc ludes ti me to whet her or

n ot a n LE A in th e Sta te has re cords fr om a not her Stat e fo r a mi gr ant s tu dent a nd ent er

i ndic at e it in th e Stat e' s ME P s ys te m

Data Subm is si on On ce p er S EA 50 SEA

s 3 6 1 ,8 00 Th is e st im at e inc ludes fo r eac h SEA to m odif y th eir Stat e ME P s ys te m and MS IX

i nt er fa ce to co llec t a nd
su bm it a n ew MD E to i ndic at e whet her or

n ot Ou t-o f-Sta te s chool
re co rds a re p re se nt

a t a n LEA

fo r a mi gr ant s tu dent

. Data Subm is si on Wi th in 10

day s of docum ent ing
a child' s eligibility 50 SEA s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e collec te d MD Es to M SI X

To ta l ov er 3 Y ears 937 46, 828 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 5 23 An nualiz ed Ave rage 312 15, 609 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 2 8

### 10



### End of Term Submission **s.** The annualized burden of the requirement to collect and submit updated and newly availab le 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 Submission**  **s.** 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 mi gratory child has chan ged 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. **Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Data Collec ti on Wi th in 30

day s of th e end of a te rm 50 SEA

s 1 7, 477 8 73, 834 Th is e st im at e inc ludes ti me to
co llect n ewly a va ilable MD E inf or at ion fo r e ach eligible mi grant st udent i n th e Sta te a nd ent er

i t i nt o th e Stat e' s ME P s ys te m Data Subm is si on Wi th in 30

day s of th e end of a te rm 50 SEA

s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e collec te d MD Es to M SI X To ta l ov er 3 Y ears 17, 477 873, 834 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 8. 4 420 An nualiz ed Ave rage 5, 826 291, 278 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 2. 8 140

**Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Data Collec ti on Wi th in 4 day s of re ce iving not if ic at ion fr om M SI X th at
a mi grat ory ch ild has ch anged
res idenc e 50 SEA s 7 2 3 ,5 83 Th is e st im at e inc ludes ti me to
co llect n ew MD E i nf

or at ion th at

h as becom e av

ailable fo r m igr ant st udent s ince th e las t s ubm is si on to MS IX a nd ent er

i t i nto th e Sta te 's ME P s ys te m

Data Subm is si on Wi th in 4 day s of re ce iving not if ic at ion fr om M SI X th at
a mi grat ory ch ild has ch anged
res idenc e 50 SEA s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e collec te d MD Es to M SI X

To ta l ov er 3 Y ears 72 3, 583 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 0 2 An nualiz ed Ave rage 24 1, 194 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 0 1

### 11



### Parental Request to SEAs for **MSIX Data Correction**

**.** The ann ualized 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 o ngoing process, and the burden remains at a constant level in each of the three years. **Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Dat a Collec ti on Wi th in 4 day s of det er mi nat ion to co rre ct d at a su bm itte d to MS IX 50 SEA s 1 .9 9 4 Th is e st im at e inc ludes e ffo rt to
co rre ct i nf

orm at ion pr ev

ious ly ent er ed in th e Sta te 's M EP s ys te m

Dat a Subm is si on Wi th in 4 day s of det er mi nat ion to co rre ct d at a su bm itte d to MS IX 50 SEA s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e correct ed dat a to M SIX

To ta l ov er 3 Y ears 1. 9 94 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 0 0 An nualiz ed Ave rage 0. 6 31 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 0 0

**Ac tiv**  **ity Fr**  **eq ue**  **nc y of** 

**Re sp**  **ons e**  **Nu mb**  **er of** 

**Re sp**  **onde nts**  **Ave rag**  **e**

**Ho ur**  **s pe**  **r Re**  **sp onde**  **nt Tot**  **al H**  **our s** 

**ov er**  **3 Ye**  **ars De**  **scri pt**  **ion** Dat a Collec ti on Wi th in 10

day s of a reques t fo r inf or ma ti on fr om th e Depart me nt 50 SEA s 0 .2 1 1 Th is e st im at e inc ludes e ffo rt to
re sp ond to a re ques t fro m th e Depart me nt

to c orrect

o r a me nd dat a pr ev

ious ly e nt er ed in th e St at e ME P s ys te m and su bm itte d to M SI X

Dat a Subm is si on Wi th in 10

day s of a reques t fo r inf or ma ti on fr om th e Depart me nt 50 SEA s - - It i s es ti ma te d th at th er e is n o addit ional ef

fo rt to e lec tro nic ally
su bm it th e correct ed dat a to M SIX

To ta l ov er 3 Y ears 0. 2 11 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 0. 0 0 An nualiz ed Ave rage 0. 1 4 Pe rs on Ye ars (a t 2 ,0 80 hours /y ear ) 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 supplem entary 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:**

Am ortized 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 $ 31 8,892

. The calculations use an average cost of $ 33.0 2 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 Migrat ory 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. **An nua**  **lize d**  **Burde n f** 

**or Al**  **l Re**  **sp onde**  **nts An**  **nua lize**  **d Cos**  **t Na**  **ti ona**  **lly @$**  **33. 02**  **Cos**

**t pe**  **r SE**  **A @$**  **33. 02**  1 Sta rt -up Dat a Su bm issi on 21, 651 714, 901 $ 25, 532

$ 2 Newl y D oc ument ed Migr ator y C hildren 109, 435 3, 613, 529 $ 72, 271

$ 3 Newl y D oc ument ed Migr ator y C hildren (S ec ondary Stu dent s) 26, 664 880, 440 $ 17, 609

$ 4 Newl y D oc ument ed Migr ator y C hildren (Out o f Sta te R ec ords ) 15, 609 515, 420 $ 10, 308

$ 5 En d of

T erm Su bm issio n 291, 278 9, 618, 004 $ 192, 360

$ 6 Change of

R es idenc e Submis sio n 1,194 39, 438 $ 789

$ 7 MSI X Dat a Correc ti on 31 1, 032 $ 21

$ 8 Res pons e to th e D epart me nt 4 124 $ 2

$ **Annua lized T**  **ot al**  **f**

**or a ll SE**  **As 465,**  **866 15,**  **382, 888**  **$ 318,**  **892**

**$** Av erage per 1, 000 Eligible Chi ldren (of 4 18, 643 ch ildren) 1,113 36, 744. 64 $ **By R**  **ep ort**  **ing A**

**ti vity** 

**` Na**  **tiona lly**  **Pe r**  **SE A** 

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 6 2, 691 3 0. 1 $ 2 ,0 70, 044 2 ,2 39 1 .1 $ 7 3, 930

Dat a Su bm is si on 2 ,2 61 1 .1 $ 7 4, 658 8 1 0 .0 $ 2 ,6 66

To ta ls 64, 952 31 2, 144, 702 $ 2, 320 1. 1 76, 596 $ **Annua lize**  **d A**

**vg**
**. 21,**  **651 10**  **714, 901**  **$ 773**  **0. 4**  **25, 532**  **$**

**Na tiona**  **lly Pe**  **r SE**  **A**

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 3 28, 304 1 58 $ 1 0, 840, 586 6 ,5 66 3 .2 $ 2 16, 812

Dat a Su bm is si on - - $ - - - $ -

To ta ls 328, 304 158 10, 840, 586 $ 6, 566 3. 2 216, 812 $ **Annua lize**  **d A**

**vg**
**. 109,**  **435 53**  **3, 613,**  **529 $**  **2, 189**  **1. 1**  **72, 271**  **$**

### 13



### 3. Newly Documented Migra **tory Children**  **with Previous Secondary Records in Same State** 

**4. Newly Documented Migra tory Children wit**  **h Secondary Records from Another State** 

**5 . End of Term Submission**  **s**

**6. Change of Residence Submission Na**  **tiona lly**  **Pe r**  **SE A** 

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 7 9, 992 3 8 $ 2 ,6 41, 320 1 ,6 00 0 .8 $ 5 2, 826

Dat a Su bm is si on - - $ - - - $ -

To ta ls 79, 992 38 2, 641, 320 $ 1, 600 0. 8 52, 826 $ **Annua lize**  **d A**

**vg**
**. 26,**  **664 13**  **880, 440**  **$ 533**  **0. 3**  **17, 609**  **$**

**Na tiona**  **lly Pe**  **r SE**  **A**

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 4 5, 028 2 2 $ 1 ,4 86, 825 9 01 0 .4 $ 2 9, 736

Dat a Su bm is si on 1 ,8 00 1 $ 5 9, 436 3 6 0 .0 $ 1 ,1 89

To ta ls 46, 828 23 1, 546, 261 $ 937 0. 5 30, 925 $ **Annua lize**  **d A**

**vg**
**. 15,**  **609 8**  **515, 420**  **$ 312**  **0. 2**  **10, 308**  **$**

**Na tiona**  **lly Pe**  **r SE**  **A**

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 8 73, 834 4 20 $ 2 8, 854, 013 1 7, 477 8 .4 $ 5 77, 080

Dat a Su bm is si on - - $ - - - $ -

To ta ls 873, 834 420 28, 854, 013 $ 17, 477 8. 4 577, 080 $ **Annua lize**  **d A**

**vg**
**. 291,**  **278 140**  **9, 618,**  **004 $**  **5, 826**  **2. 8**  **192, 360**  **$**

**Na tiona**  **lly Pe**  **r SE**  **A**

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 3 ,5 83 2 $ 1 18, 315 7 2 0 .0 $ 2 ,3 66

Dat a Su bm is si on - - $ - - - $ -

To ta ls 3, 583 2 118, 315 $ 72 0. 0 2, 366 $ **Annua lize**  **d A**

**vg**
**. 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 compone nts : (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, maintai ning, 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 w hich 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 in formation 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. **Na tiona**  **lly Pe**  **r SE**  **A**

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 9 4 0 $ 3 ,0 96 1 .9 0 .0 $ 6 2

Dat a Su bm is si on - - $ - - - $ -

To ta ls 94 0 3, 096 $ 1. 9 0. 0 62 $ **Annua lize**  **d A**

**vg**
**. 31**  **0 1,**  **032 $**  **0. 6**  **0. 0**  **21 $** 

**Na tiona**  **lly Pe**  **r SE**  **A**

**Tota l Hour**  **s ove**  **r 3**  **Ye ars**  **Pe rso**  **n Y ears**  **Co st**  **@ $33.**  **02 pe**  **r Hour**  **Tota l H**  **our s** 

**ove r**  **3 Ye**  **ars Pe**  **rso n Y**  **ears Cos**  **t @ $33.**  **02 pe**  **r Ho**  **ur** Dat a Collec ti on 1 1 0 $ 3 71 0 .2 0 .0 $ 7

Dat a Su bm is si on - - $ - - - $ -

To ta ls 11 0 371 $ 0. 2 0. 0 7 $ **Annua lize**  **d A**

**vg**
**. 4**  **0 124**  **$ 0.**  **1 0.**  **0 2**  **$**

### 15



### A13. The only costs to respondents are those shown above for staff time for d ata c ollection 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 record

keeping 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 Y ear 2006 and implemented in Fiscal Year 2007. Funding in Fiscal Years 2007 through 201 1 pa id for acquisition and maintenance until the contract expire d on September 29, 2011. A new contract for the continued operation and maintenance of MSIX was awarded on August 1 , 2011 and expires on Ju ly 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 Was hington, 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 F iscal Year 201 5 . 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 St**  **af f**  **Ti me**  **in Gove**  **rnm en**  **t FTE**  **s ED**  **St af**  **f Co**  **st s**  **(Loa de**  **d wi**  **th Be**  **ne fi**  **ts , 3**  **% an**  **nua l**  **in cre**  **as e)**  **MSIX C ontra**  **ct**

**Co st**  **s Tot**  **al s**  **Hi st**  **ori ca**  **l C os** 

**ts** FY 2 006 2. 20

- $ 7, 980, 831

$ 7, 980, 831

$ FY 2 007 2. 20 264, 440 $ 3, 129, 097

$ 3, 393, 537

$ FY 2 008 2. 20 272, 373 $ 3, 262, 624

$ 3, 534, 997

$ FY 2 009 2. 20 280, 544 $ 3, 034, 085

$ 3, 314, 630

$ FY 2 010 2. 20 288, 961 $ 3, 161, 144

$ 3, 450, 105

$ FY 2 011 2. 20 297, 630 $ 3, 632, 746

$ 3, 930, 376

$ FY 2 012 2. 20 306, 558 $ 2, 660, 856

$ 2, 967, 415

$ To ta l 1, 710, 506 $ 26, 861, 385

$ 28, 571, 892

$ An nualiz ed To ta l 244, 358 $ 3, 837, 341

$ 4, 081, 699

$ **Ne xt**  **3 Y**  **ear s**  FY 2 013 2. 20 315, 755 $ 2, 702, 637

$ 3, 018, 393

$ FY 2 014 2. 20 325, 228 $ 2, 469, 194

$ 2, 794, 422

$ FY 2 015 2. 20 334, 985 $ 2, 459, 042

$ 2, 794, 027

$ To ta l 975, 968 $ 7, 630, 874

$ 8, 606, 842

$ **An nua**  **lize d**  **Tot al**  **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 201 3 thr ough 201 5

. 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 collecti on. 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 operati ng 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 by

pass contract ended. The data burden for the by

- pass states is being included due to the fact that the SEAs
asso ciated with these states ma y 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 prac tices 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 proj ect, 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 techni ques. 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 t he 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 Fo rm 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.