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Race to the Top Program Review Protocols:

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

A.1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. Attach a 

copy of the appropriate section of each statute and regulation mandating or authorizing 

the collection of information.

The American Recovery and Reinvestment Act of 2009 (ARRA) provided $4.3 billion 

for the Race to the Top Fund (referred to in the statute as the State Incentive Grant Fund), 

of which approximately $4 billion was used to fund comprehensive statewide reform 

grants under the Race to the Top program. The U.S. Department of Education 

(Department) awarded Race to the Top grants in two phases. On March 29, 2010, at the 

conclusion of Phase 1, the Department announced Race to the Top grants for two states. 

Delaware and Tennessee received their grant awards on June 14 and July 28 respectively. 

On August 24, 2010, at the conclusion of Phase 2, the Department announced Race to the 

Top grants to an additional 9 states and the District of Columbia. All Phase 2 grants were 

awarded on September 24, 2010. The Department has supported grantees as they have 

implemented ambitious reform agendas through Race to the Top. Specifically, the 

Implementation and Support Unit (ISU) at the Department has differentiated its approach

to supporting grantees based on individual State needs, as well as supported States to 

work with each other and with experts from around the nation to achieve and sustain 

educational reforms.

In order to fulfill our programmatic oversight responsibilities, the Department has 

developed and implemented a monitoring (program review) protocol that is aligned to the 

Race to the Top selection criteria and absolute priorities previously established and 

published in the Federal Register. Grantees are required to submit regular progress 

updates on the status of the performance measures included in their proposals, as well as 

information regarding fiscal oversight and accountability of federal funds. Grantee 

responses provide the information required for the Department to inform State-specific 

ongoing performance management discussions in order to make the necessary and 

immediate adjustment to program implementation and support, as well as provide 

appropriate and timely updates to the public on the progress of grantee’s program 

implementation. Similar to all discretionary grants, Race to the Top grantees are eligible 

to receive a no-cost extension that allows for one additional year to implement projects 

under their approved plans. As a result of the no cost extension period, we are seeking an 

extension of a previously approved collection. 
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A.2. Indicate how, by whom, and for what purpose the information is to be used. Except 

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

received from the current collection.

The Department will continue to use information collected throughout the program 

review to assess the progress of Race to the Top grantees in implementing the activities 

outlined in their approved applications and ensure compliance with statutory and 

Department fiscal regulations.

Based on the responses the Department has received, the Progress Update questions are 

eliciting the level of detail and quality of responses desired, as well as information on 

parts of the plan that do not include a defined set of goals and performance measures. 

For example, Part A of the progress update template allows for a State to provide 

information on all aspects of its plan, including those areas that did not include a defined 

set of goals or performance measures, by eliciting information on all aspects of their plan 

that have a recent success or challenge. 

State responses, particularly those related to the question that asks for challenges or 

barriers to implementation, provide useful information for the Reform Support Network 

to ensure it supplying meaningful and relevant technical assistance to each grantee. 

Moreover, members of the Reform Support Network have been and will continue to be

involved in each grantee’s on-site review. This fosters a deeper understanding of the 

grantee’s overall plan and allows the Department to pinpoint areas in which it can 

provide support, services, or expertise to assist the State.

A.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 of using information technology to reduce burden.

The information requested under this collection will be gathered by email. The 

Department has sufficient capacity to deal with the email submissions. The information 

gathered through this process is detailed in A2.

A.4. 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.

The assurances and information requested under this collection are unique to the Race to 

the Top program, and the Department has not collected them in the past. Even in the 

event of similar or comparable information for other programs in the past, the progress 

updates are specific to the Race to the Top program and the information is specific to the 

present point in time. Therefore, any comparable information and assurances that were 

collected in the past would not satisfy the requirements for this program. The Department 

has made every effort to reduce the burden on States in producing the information. 
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A.5. If the collection of information impacts small businesses or other small entities 

(Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The Secretary certifies that this proposed action will not have a significant economic 

impact on small entities. At most, there are 11 small entities that will be impacted but the 

burden will be kept to a minimum for all grantees. 

A.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.

Race to the Top is the largest discretionary grant program ever administered by the 

Department, and continues to generate high public interest for the Department. This 

collection is critical to ensure the Department has the required information to inform 

ongoing performance management discussions with grantees in order to make the 

necessary and immediate adjustments to program implementation and support, as well as 

provide appropriate and timely updates to the public on the progress of grantee’s program 

implementation. 

A.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 which unnecessarily 

impedes sharing of data with other agencies for compatible confidential use; or

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

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

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

The Department is committed to supporting States as they implement ambitious reform 

agendas through Race to the Top. Specifically, the ISU is differentiating its approach to 

supporting grantees based on individual State needs and tailored technical assistance that 

supports States to work with each other and with experts from around the nation to 
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achieve and sustain educational reforms. Thus, ongoing communication with the 

Department is necessary to provide appropriate and timely assistance to States as they

implement their Race to the Top plans. Additionally, regular submission of progress 

updates will reduce the burden on the State when preparing for the onsite program review 

and meetings with ISU leadership. 

This collection is consistent with 5 CFR 1320.5.

A.8. If applicable, provide a copy and identify the date and page number of publication 

in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting 

comments on the information collection prior to submission to OMB. Summarize public 

comments received in response to that notice and describe actions taken by the agency in 

response to these comments. Specifically address comments received on cost and hour 

burden.

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

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

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

disclosed, or reported.

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

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

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

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

The public has previously had an opportunity to comment during the emergency and 

regular clearance period, and the Program Review protocols have been updated to reflect 

public comment. The public will also have an opportunity to comment during the public 

comment period notice, and a response summary will be provided for those comments.

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

remuneration of contractors or grantees.

No payments or gifts to respondents have been made.

A.10. Describe any assurance of confidentiality provided to respondents and the basis for 

the assurance in statute, regulation, or agency policy.

There is no assurance of confidentiality.

A.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 
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explanation to be given to persons from whom the information is requested, and any steps 

to be taken to obtain their consent.

There are no questions of a sensitive nature.

A.12. Provide estimates of the hour burden of the collection of information. 

A. Burden hours for respondents

The Department estimates that approximately 12 entities will engage in this collection. 

The average annual burden for the program review, including the Progress Updates and 

Accountability and Oversight protocols, is estimated to be 52 hours per grantee, for a 

total of 744 total annual burden hours. The burden estimate was calculated based on the 

amount of time it would take a typical grantee staff member or team of staff members to 

complete each item.

A. State Success Factors Hours (Annual)

(A)(1) Articulating State’s education reform agenda and LEA

participation in it

0

(A)(2) Building strong statewide capacity to implement, scale and 

sustain proposed plans

3

(A)(3) Demonstrating significant progress in raising achievement 

and closing gaps

3

B. Standards and Assessments

(B)(1) Developing and adopting common standards 0

(B)(2) Developing and implementing common, high-quality 

assessments

3

(B)(3) Supporting the transition to enhanced standards and highquality assessments3

C. Data Systems to Support Instruction

(C)(1) Fully implementing a statewide longitudinal data system 0

(C)(2) Accessing and using State data 3

(C)(3) Using data to improve instruction 3

D. Great Teachers and Leaders

(D)(1) Providing alternative pathways for aspiring teachers and 

principals

3

(D)(2) Improving teacher and principal effectiveness based on 

performance

3

(D)(3) Ensuring equitable distribution of effective teachers and 

principals

3

(D)(4) Reporting the effectiveness of teacher and principal 

preparation programs

3

(D)(5) Providing effective support to teachers and principals 3

E. Turning Around the Lowest-Achieving Schools

(E)(1) Intervening in the lowest-achieving schools and LEAs 0

(E)(2) Turning around the lowest- achieving schools 3
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Competitive Priority 

Emphasis on Science, Technology, Engineering, and Math 3

Additional Requirements

(a) Progress Updates - LEA 12

(b) Logistics 1

Total annual hours per grantee 52

Total annual hours 624

B. Cost to Respondents

The Department estimates that the per-hour cost for grantee employees will average $30 

per person (approximately GS-12 equivalent) per hour for a total of $1,860.00 annually. 

Each grantee will have approximately six employees collecting this information. 

A.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 startup cost component (annualized over its expected useful life); and (b) a total 

operation and maintenance and purchase of services component. The estimates 

should take into account costs associated with generating, maintaining, and 

disclosing or providing the information. Include descriptions of methods used to 

estimate major cost factors including system and technology acquisition, expected 

useful life of capital equipment, the discount rate(s), and the time period over 

which costs will be incurred. Capital and start-up costs include, among other 

items, preparations for collecting information such as purchasing computers and 

software; monitoring, sampling, drilling and testing equipment; and record 

storage facilities.

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

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

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

developing cost burden estimates, agencies may consult with a sample of 

respondents (fewer than 10), utilize the 60-day pre-OMB submission public 

comment process and use existing economic or regulatory impact analysis 

associated with the rulemaking containing the information collection, as 

appropriate.

Accountability and Oversight Requirements Hours (Annual)

Accountability and Oversight - SEA 4

Accountability and Oversight – LEA 6

Total annual hours per grantee 10

Total annual hours 120
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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.

Total Annualized Capital/Startup Cost: 0

Total Annual Costs (O&M): 0

_________________________________________

Total Annualized Costs Requested: 0

There are no start-up or annual costs (aside from salaries listed above) for this collection.

A.14. Provide estimates of annualized cost to the Federal government. Also, provide a 

description of the method used to estimate cost, which should include quantification of 

hours, operational expenses (such as equipment, overhead, printing, and support staff), 

and any other expense that would not have been incurred without this collection of 

information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a 

single table.

The Federal costs will involve managing grantee submissions continuously over the life 

of the grant. Calculations below include the costs associated with managing the 12 

grantees: 

 Grade 9: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site 

collection) = 24 + 6 = 30 hours per year x 4 employees = 120 hours at 24.74 / 

hour = $2,969

 Grade 12: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site 

collection) = 24 + 6 = 30 hours per year x 5 employees = 150 hours at 35.88 / 

hour = $5,382

 Grade 13: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site 

collection) = 24 + 6 = 30 hours per year x 1 employee =30 hours at 42.66 / hour = 

$7,679

 Grade 15: (2 hrs x 12 months for monthly submissions) = 24 hours per year x 1 

employee = 24 hours at 74.51 / hour = $1,810

Total = $17,840 per year

A.15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

The burden hours have been reduced to reflect actual grantee submissions. Grantees are 

only required to submit responses for those application sections that are applicable to 
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their plans. Therefore, the application sections that do not have plans have been removed 

from the burden calculations. 

A.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.

Some of the information collected in this program review may be analyzed with 

performance data and shared on a government website such as recovery.gov or ed.gov.

A.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.

There are no exceptions to the certification statement.

A18. Explain each exception to the certification statement identified in Item 20, 

“Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

The Department is requesting an exception to the provision certifying a reduction in 

burden for small entities because the provision does not apply. Additionally, the 

provision for certifying the use of effective and efficient statistical survey methodology

does not apply to this proposed action.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL 

METHODS

This information collection does not employ statistical methods.