EDICS Tracking and OMB Number: (XXXX) 1840
- 0113 Revised: 03/2 5 /2015

RIN Number: XXXX
- XXXX (if applicable) **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  Application for Grants under the Historicall y Black Colleges and Universities (HBCU) and Student Aid Student Aid and Fiscal Responsibility Act (SAFRA) of 2009 Programs **(CFDA No.: 84.031B)**

**A. Justification**  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that neces sitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review type of th e collection (new , revision, extension, reinstatement with change, reinstatement without change) . If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The Office of Postsecondary Education is requesting reinstatement of this previously approved application which will be needed to make new awards in fiscal years (FY) 2015 for the Student Aid and Fiscal Responsibility Act (SAFRA) of 2009 program and 2017 f or the Strengthening Historically Black Colleges and Universities (HBCU) program

. The HBCU and SAFRA Programs are required by legislation to collect institutional data during the Phase I process to retain benefits annually. The SAFRA program begins a new grant cycle in FY 2015 and the application period is anticipated to take place in July of 2015. The previous application was discontinued as ofMay 31, 2014. The authorizing statutes for th ese program s ( Title III, Part B, Sections 321

- 327 of the Higher Education Act, as amended (20 U.S.C. 1060

- 1063c) for the HBCU Program ; Title III, Part F, Section 371 of the Higher Education Act, as amended (20 U.S.C. 1067q) for the SAFRA Program ; and the governing regulations (34 CFR Part 6 08 ) require the collection of this information to determine the applicant’s eligibility. Link to applicable Legislation &Regulations: http://www2.ed.gov/programs/iduestitle3b/legisla tion.html Minor changes to the application have been made since OMB’s last review and approval of the form. The dates and minor edits to the language were made to ensure accuracy and clarity. These clarifications do not require additional data from the a pplicant. The collection of the information requested in the proposed application form is necessary to allow eligible historically Black institutions of higher education to apply for grant funds annually under the HBCU program s .

1 Please limit pasted text to no longer than 3 paragraphs.Page 2

2. Indicate how, b y whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. The HBCU Title III, Part B Program is authorized by Section 322 of the HEA, as amended by the Higher Education Opportunity Act (HEOA) of 2008, and in the Code of Federal Regulations (34 CFR 608). The HBCU Program is a discretionary grant that provides f

ormula based awards to establish or strengthen the physical plants, finan cial management, academic resources, and endowments

. Institutions of higher education must be legally designated as a Title III eligible Historically Black College and University to apply for funding. In order to receive continuation funding, institution s must submit statutor il

y required data for program staff to calculate award amounts and must maintain their accreditation. T he data collection of information is required under the program regulations 34 CFR Section §608.31 and Title III, Section 324 of the HEA, as amended for determining the level of funding awards for an institution. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology , e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe any consideration given to using technology to reduce burden. The HBCU and SAFRA program collection of information will be one hundred percent electronic, thereby minimizing burden to the fullest. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information already available cannot be used or modified for use for the purposes described in Item 2 above. The information submitted in each application is unique to each respondent. Moreover, the information changes annually. No other existing information collection can serve the purposes described in item 2. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not - for
- profit enterprise that is independentl y owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less than 50,000. Not applicable

– small businesses or other small entities are not impacted by this collection.Page 3

6. Describe the consequences to Federal program or policy activities i f the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. In order for the Department to determine the level of funding for an institution, the Phase I data collection of information is required under the program regulations 34 CFR

– Section §608.31 and Title III, Section 324 of the HEA, as amended

. If the requested information is not collected annually, grants cannot be awarded in accordance with the guidelines outlined in Title III , Part B and Part F of the legislation. If the collection were not conducted annually, appropriated funds could not be spent. 7. Explain any

special circumstances that would cause an information collection to be conducted in a manner:

 requiring respondents to report information to the agency more often than quarterl y;

 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, grant - in
- aid, or tax records for more than three years;

 in connection with a statistical survey , that is not designed to produce valid and r eliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;

 that includes a pledge of confidentiality that is not supported by

authority establis hed in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

 requiring respondents t o submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law. There are no special circumstances that would require the collection to be conducted as outlined above in question 7. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection p rior to submission to OMB. Summarize public comments received inPage 4

response to that notice and describe actions taken by the agency

in response to these comments. Specificall y address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability

of data, frequency

of collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), and on the data elements to be recorded, disclosed, or repo rted. 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. We publish the applicable 30

- day Federal Register notice required for public comment. Additionally, annual consultations and reviews have occurred with representatives of the HBCUs regarding the data collection instrument, and instructions provided during annual technical assistance workshops for all grantees, and during individual on

-site visits. 9. Explain any

decision to provide any pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. No gifts or payments will be provided to respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for th e assurance in statute, regulation, or agency policy
. If personally

identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality
. If there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data

. The Department’s disclosure policies adhere to the provi sions of the Privacy Act and n o assurances of confidentiality are provided

. 11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency

conside rs the questions necessary , the specific uses to be made of the information, the explanation to be

2 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A
- 108

– Privacy Act Implementation

– Guidelines and Responsibilities, OM B Circular A
- 130 Appendix I

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

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

– Safeguarding Personally Identifiable Information, OM : 6
- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)Page 5

given to persons from whom the information is requested, and any steps to be taken to obtain their consent. Questions of a sensitive nature are not included in this information collection.
12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for
- profit, private sector

– not - for
- profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden ty pe : recordkeeping, reporting or third party

disclosure. All narrative should be included in item 12. Unless directed to do so, 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 varia nce. Generally, estimates should not include burden hours for customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of informati on, 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. Estimated burden hours for thi s collection of information are 24 burden hours pe r respondent over five years and we estimate 97 respondents. Applications will be submitted electronically

. Therefore, we expect an estimated total of 2,328 burden hours per annual submission. Annual Burden Hours: Phase I

– 16 hours

– annually Phase II

– 40 hours

– once every five years Estimated Individual Average Annual Burden Hours: Year 1 56 (new application every five years) Year 2 16Page 6 Year 3 16 Year 4 16 Year 5 16

120 hours per applicant 120 hours per applicant divided by 5 years = 24 average burden hours per applicant each year. 97 applicants x 24 burden hours = 2,328 2,328 = total average annual burden hours for all applicants Of the 97 estimated respondents, 52 are public institutions and 45 are private, non

- profit institutions. The total average annual burden hours f or public institutions are 1,248

. The total average annual burden hours for private, n on - profit institutions are 1 , 080. Average Estimate of Cost to Applicant s:

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start
- up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the t ime period over which costs will be incurred. Capital and start - up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part o f 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 anal ys is assoc iated with the rulemaking containing the information collection, as appropriate. Professional staff (1 personnel X 40 hours X $52 per hour) = $2, 08 0 Support staff (2 personnel X 16 hours X $50 per hour) = $1,60 0 Total Professional cost: $2,080 Total Support cost: +$ 1,600 **Total: $3,680** Page 7

 Generally , estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : The total for the capital and start

- up cost components for this information collection is zero. This information collection will not require the purchase of any capital equipment and will not create any start
- up costs. 14. P rovide 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. **Estimated annual cost to the Federal Government** Development and Approval Process (1 staff x 75 hours x $52 per hour) $3,90 0 Printing Phase I Formula Worksheets (194 Worksheets (2 pages) x $1 (per page ) $194 Monitoring of Grants (160 day s x 6 staff x 280 hours) $268,800 World Wide Web Preparation for Posting (4 hours x 1 staff x $52 per hour) **$** 208 ( 40 hours x 1 staff x $52 per hour) $2, 0 8 0 Staff time to review and approve fundi ng recommendation (20 hours x 1 staff x $52 per hour) $1,04 0 Staff time to generate, approve, and issue grant awards. (48 hours x 1 staff x $ 5 2 per hour) $2, 496 Processing Applications 10 hours per award x 97 awards = 970/6= 162 hours per person 6 staff x $50 x 162 hours= $48,600 $ 48,600
**Total estimated cost to the Federal Government $327,318** 

15. Explain the reasons for any program changes or adjustments. Generall y, adjustments in burden result from re
- estimating burden and/or from economic phenomenon outside of anPage 8

agency ’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated b y type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty pe of collection (new, revision, extension, reinstatement with cha nge, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)
. This is a reinstatement of a previ ously discontinued collection . T herefore, all burden is new. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. Results of the collected information will not be published. 17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that displ ay would be inappropriate. Not applicable. This report will display the expiration date for the OMB approval of the information collection. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. Not applicable. There are no exceptions to the certification statement.