EDICS Tracking and OMB Number: (XXXX) 1840-0113 Revised: 03/25/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Application for Grants under the Historically 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 necessitate the collection. Attach a hard copy of the appropriate section of 

each statute and regulation mandating or authorizing the collection of information, or you may provide a 

valid URL link or paste the applicable section1. Specify the review type of the collection (new, revision, 

extension, reinstatement with change, reinstatement without change). If revised, briefly specify the 

changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.

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 for 

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 of May 31, 2014.

The authorizing statutes for these programs (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 608) require the 

collection of this information to determine the applicant’s eligibility. Link to applicable 

Legislation & Regulations: 

http://www2.ed.gov/programs/iduestitle3b/legislation.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 applicant. 

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 programs.

 

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Please limit pasted text to no longer than 3 paragraphs.
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2. Indicate how, by whom, and for what purpose the information is to be used. Except for a 

new collection, indicate the actual use the agency has made of the information received 

from the current collection.

The 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 formula based awards to establish or strengthen the physical plants, financial 

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, institutions 

must submit statutorily required data for program staff to calculate award amounts and

must maintain their accreditation. The 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 specifically why any 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 

independently owned and operated and is not dominant in its field; or (3) a small 

government jurisdiction, which is a government of a city, county, town, township, school 

district, or special district with a population of less than 50,000.

Not applicable – small businesses or other small entities are not impacted by this 

collection.
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6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to 

reducing burden.

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 quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

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

document;

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

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

in statute or regulation, that is not supported by disclosure and data security policies 

that are consistent with the pledge, or that unnecessarily impedes sharing of data with 

other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to 

protect the information’s confidentiality to the extent permitted by law.

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 by 5 CFR 1320.8(d), soliciting comments on the information 

collection prior to submission to OMB. Summarize public comments received in 
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response to that notice and describe actions taken by the agency in response to these 

comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, 

disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or 

those who must compile records should occur at least once every 3 years – even if the 

collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

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 payment 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 any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information 

(PII) is being collected, a Privacy Act statement should be included on the instrument. 

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

Assessment was completed as indicated on the IC Data Form. A confidentiality statement 

with a legal citation that authorizes the pledge of confidentiality should be provided.2If 

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

sufficient with respect to confidentiality. If there is no expectation of confidentiality, 

simply state that the Department makes no pledge about the confidentially of the data.

The Department’s disclosure policies adhere to the provisions of the Privacy Act and no 

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 considers 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, OMB Circular A-130 Appendix I – Federal Agency 

Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy 

Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 –

Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)
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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 type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden 

was estimated, including identification of burden type: recordkeeping, reporting or 

third party disclosure. All narrative should be included in item 12. Unless directed to 

do so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary

widely because of differences in activity, size, or complexity, show the range of 

estimated hour burden, and explain the reasons for the variance. Generally, estimates 

should not include burden hours for customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

Estimated burden hours for this collection of information are 24 burden hours per 

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 16
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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 for public institutions are 1,248. 

The total average annual burden hours for private, non-profit institutions are 1,080.

Average Estimate of Cost to Applicants:

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting 

from the collection of information. (Do not include the cost of any hour burden shown in 

Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into 

account costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

Professional staff

(1 personnel X 40 hours X $52 per hour) = $2,080

Support staff

(2 personnel X 16 hours X $50 per hour) = $1,600

Total Professional cost: $2,080

Total Support cost: +$1,600

Total: $3,680
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 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. 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.

Estimated annual cost to the Federal Government

Development and Approval Process

(1 staff x 75 hours x $52 per hour)

$3,900

Printing Phase I Formula Worksheets

(194 Worksheets (2 pages) x $1 (per page)

$194

Monitoring of Grants

(160 days 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) $2,080

Staff time to review and approve funding recommendation 

(20 hours x 1 staff x $52 per hour)

$1,040

Staff time to generate, approve, and issue grant awards.

(48 hours x 1 staff x $52 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. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 
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agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes 

a collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden 

changes should be disaggregated by type of change (i.e., adjustment, program change due to 

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

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

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

This is a reinstatement of a previously discontinued collection. Therefore, all burden is new.

16. For collections of information whose results will be published, outline plans for tabulation 

and publication. Address any complex analytical techniques that will be used. Provide the 

time schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

Results of 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 display 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.