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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

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

authorizing the collection of information.

One of the core administrative activities of the U.S. Department of Education’s (ED) office of International 

and Foreign Language Education (IFLE) is to award continuation grants under the fourteen discretionary 

programs cited in this information collection. Our capacity to conduct this activity, however, is contingent 

upon the availability of information that grant recipients submit in annual performance reports. The 

Education Department General Administrative Regulations (EDGAR) stipulates that a recipient that wants 

to receive a continuation award shall submit a performance report that provides the most current 

performance and financial expenditure information. The International Resource Information System 

(IRIS), the online reporting system described in this statement, provides grantee institutions with a 

centralized repository for inputting their performance report data and narrative information.

There are a number of additional legal or administrative requirements that make this collection necessary, 

including the program reporting and evaluation requirements in the Department of Education’s Visual 

Performance Suite (VPS) and the Government Performance and Results Act (GPRA) of 1993. VPS is the 

Department’s strategic planning performance data collection system. IRIS gathers and maintains the 

information that program managers use to help them align program operations level with the 

Department’s overall strategic goals and objectives. The VPS contains the performance and efficiency 

measures for each of the 14 programs as well as the results of each measure, if available at this time. 

The GPRA requires all federal agencies to develop annual performance plans for their programs, in which 

the agencies specify the outcomes to be achieved, the indicators of success, and strategies to be 

followed to accomplish the plan. GPRA further requires the submission of an annual performance report 

to Congress.

IRIS was initially designed and implemented to respond to the GPRA mandate, that by Fall 2002, all 

federal agencies would have demonstrated that they had developed consistent and effective annual data 

collections with systematized evaluation for their respective programs. In 1998, IFLE funded a project to 

meet this mandate. The development of IRIS made a fundamental change in how performance 

information and data for the fourteen IFLE programs, authorized under Title VI of the Higher Education 

Act and section 102(b)(6) of the Mutual Educational and Cultural Exchange Act, also known as FulbrightHays (F-H), was collected. IFLE used this project to replace the paper collection instruments with an 

online performance reporting instruments.

Teams of IFLE staff as well as grantees have spent the past seven months reviewing the instruments, 

making recommendations for changes, and identifying areas of improvement. 

IRIS allows Title VI/F-H program grantee institutions to submit performance report information and data, 

including project abstracts, project status, GPRA information, and budget information that are more 

comprehensive, and comparable than the traditional paper reports. The reports provide IFLE

management and program officers with valuable performance information to enable them to assess 

program effectiveness. The system also captures the data that is used for performance measurement.
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This information collection package requests continued approval for the performance objectives and 

measures for all fourteen programs: (1) American Overseas Research Centers Program (AORC), (2) 

Business and International Education Program (BIE), (3) Centers for International Business Education 

(CIBE), (4) Foreign Language and Area Studies Fellowships Program (FLAS), (5) Institute for 

International Public Policy Program (IIPP), (6) International Research and Studies Program (IRS), (7) 

Language Resource Centers Program (LRC), (8) National Resource Centers Program (NRC), (9) 

Technological Innovation and Cooperation for Foreign Information Access Program (TICFIA), (10) 

Undergraduate International Studies and Foreign Language Program (UISFL). ), (11) Fulbright-Hays 

Doctoral Dissertation Research Abroad Program (DDRA), (12) Fulbright-Hays Faculty Research Abroad 

Program (FRA), (13) Fulbright-Hays Group Projects Abroad Program (GPA), and (14) Fulbright-Hays 

Seminars Abroad Program (SA).

The statutes and regulations that necessitate this collection include the following and appear in 

Attachment A:

 The Higher Education Act of 1965, as amended, Title VI Parts A, B and C;

 The Mutual Educational and Cultural Exchange Act of 1961 (The Fulbright-Hays Act), section 

102 (b)(6);

 34 CFR Parts 655, 656, 657, 658, 660, 661, 662, 663, 664, and 669; and

 Education Department General Administrative Regulations (EDGAR), Part 74, section 74.51 

and Part 75, sections 75.118, 75.253, 75.720.

Note: In fiscal year (FY) 2011, IFLE contracted with Berkeley Policy Associates to develop logic models 

and new GPRA measures for all 14 of the programs included in this collection. The new GPRA measures 

are currently under review by OMB, and were not approved in time to include them as part of this 

collection. IFLE intends to resubmit this package for clearance once the measures are approved, so that 

they can go into effect as soon as possible.

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.

IFLE management uses the data and information generated from the system to inform the Title VI/F-H 

program monitoring, evaluation, and budget processes. Management also uses the data to calculate the 

performance and efficiency measures required by OMB. Reports are run in response to high-level 

requests within the Department for program information and statistics. The data in the system is being 

used externally by grantees and contractors to assess program effectiveness and to make 

recommendations for program administration and technical (including system) improvements.

IFLE program officers use the system information and data since they need reliable, comparable 

information about their grantees’ projects in order to determine whether grantees are completing grantfunded activities in compliance with the approved grant applications, and whether grantees are expending 

grant funds for allowable and allocable costs. The program officers’ assessments of substantial progress 

provide the basis for making continuation awards in subsequent budget periods for the grant cycle.

The Help Desk is the primary source for systems related questions and concerns. Program officers also 

provide technical assistance on how to access the system’s screens.

Grantee institutions use the IRIS reporting system to input program performance information, and to 

submit that information to ED as part of the annual report for obtaining continuation awards from ED. 

Currently, grantees are making a concerted effort to respond to reporting requirements by providing 

additional quantitative data through the IRIS reporting system. In doing so, grantees collectively make a 

powerful statement regarding the relevance of their projects and the importance of international education 

programs overall. In addition, the Congress and OMB use the information collected by the IFLE reporting 

system to determine the effectiveness of IFLE programs.
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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 IRIS reporting system is web-based. Grantees funded under the 14 IFLE programs submit their 

performance reports using the system. This is the most efficient way to collect and review grantee 

performance reports. It also allows for more rapid dissemination of the data collected as it is collected via 

the system and stored in a database. Select data elements from the reports are then made available to 

the general public on a contractor-maintained public web site.

This is the fifth clearance of this reporting system so the use of a web-based reporting system has been 

in practice for a number of years. It has worked well and continues to be improved so we are continuing 

its use.

Continuing to collect information electronically in a system that is being enhanced provides additional 

reductions in burden on the grantees.

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 IRIS reporting systems collects performance report data from grantees and is the only mechanism by

which this data is collected. The information is not available through any other means. Therefore there is 

no duplication.

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

8b of IC Data Part 2), describe any methods used to minimize burden.

The collection does not impact small businesses or other small entities.

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.

34 CFR § 74.51 and §75.118 require that grantees submit performance reports in order to provide the 

information required in §74.51(d)(1)-(3) and in order to provide program staff with enough information to 

determine that substantial progress has been made towards the project’s goals (§75.118(a)) so that 

continuation funding may be awarded. The IRIS reporting system is the only mechanism for collecting 

the information needed to monitor and administer these grant programs. The system greatly facilitates 

much more efficient program monitoring than the earlier paper-based reporting process.

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;
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 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 tht it has instituted procedures to 

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

None of the special circumstances listed applies to this information collection clearance request.

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.
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IFLE maintains an ongoing dialogue with the constituency regarding the use, improvements, and 

enhancements of the IRIS reporting system. Many of the suggestions are incorporated in the proposed 

screens.

Program officers receive queries from grantees on the system that are then shared with management and 

the contractor so that if there is a recurring question, it can be addressed. The help desk also tracks 

queries and again, if there is a recurrence, the contractor shares it with management and action is taken 

to improve the process.

Refer to Part 2 for copies of the proposed IFLE reporting system screens, and Attachment C for a 

spreadsheet documenting the proposed changes to the current system.

We publish the applicable 60 and 30 day Federal Register notices allowing for public comment.

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

remuneration of contractors or grantees.

This is not applicable as no payments or gifts are provided to respondents.

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

the assurance in statute, regulation, or agency policy.

Grantee institutions are not provided any assurance of confidentiality because confidentiality is not 

authorized in the applicable statutes, regulations, or agency policy. None of the 14 programs collects or 

will collect information that is covered under the Privacy Act of 1975. The data collected consists solely of 

quantitative data regarding individual program objectives and qualitative information relating to grantee 

status and accomplishment of program goals.

ED assures the protection of fellow/participant data by using a password-protected system. Passwords 

will automatically be generated and assigned to authorized administrators at the FLAS, FRA, DDRA, and 

GPA grantee institutions upon creation of their IRIS reporting system account. When the grantee 

institutions submit the FLAS, FRA, DDRA, and GPA institutional lists, the IRIS reporting system will create 

a password for each fellow/participant on each institutional list. The fellow/participant uses the assigned 

password to complete and submit his or her performance reporting, including a language self-evaluation 

to ED. The self-evaluation portion of the report is available only to that fellow/participant and the ED 

program officers. Project directors will be able to view the academic portion of the fellow’s reports.

Similarly, information in the NRC, IIPP, UISFL, BIE, CIBE, AORC, LRC, IRS, TICFIA, SA and the 

institutional portion of FRA, DDRA, and GPA performance reports is password-protected. The IRIS 

reporting system will automatically generate and assign a password to the project director at the grantee 

institutions upon creation of their IRIS account. Using their passwords, these administrators will have 

access to the system to input the names of other authorized users (who will have data input rights but not 

the ability to submit any reports), as well as complete and submit the performance reports to ED. After 

the performance reports are electronically submitted, the system prohibits access by one grantee 

institution to another grantee institution’s performance report.

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 given to persons from whom the information is requested, and any 

steps to be taken to obtain their consent.
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This collection does not ask questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement 

should :

 Indicate the number of respondents, frequency of response, annual hour 

burden, and an explanation of how the burden was estimated. Unless 

directed to do so, agencies should not conduct special surveys to obtain 

information on which to base hour burden estimates. Consultation with a 

sample (fewer than 10) of potential respondents is desirable. If the hour 

burden on respondents is expected to vary widely because of differences in 

activity, size, or complexity, show the range of estimated hour burden, and 

explain the reasons for the variance. Generally, estimates should not include 

burden hours for customary and usual business practices.

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

burden estimates for each form and aggregate the hour burdens in item 16 of 

IC Data Part 1.

 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 not be included in Item 14.

Annual Performance Report Estimated Burden for Grantees from the 14 IFLE Programs

Program

Number of 

Respondents

Freq. 

Reports/Year

Est. Avg. 

Hours 

/Response

Est. 

Number 

of Total 

Hours

Est. Hourly

Wage of 

Respondent

Est. 

Total 

Cost

Number of 

Responses

Est. Cost 

per 

Respondent

AORC 10 2 20 7.5 150 $45 $675 $6,750 

BIE 50 2 100 10 1000 $45 $900 $45,000 

CIBE 33 2 66 15 990 $45 $1,350 $44,550 

DDRA 

Fellow 150 2 300 1 300 $20 $40 $6,000 

DDRA 

Director 98 1 98 2 196 $40 $80 $7,840 

DDRA 

Language 

Instructor 150 1 150 0.5 75 $30 $15 $2,250 

FLAS 

Fellow 1809 1 1809 1 1809 $20 $20 $36,180 

FLAS 

Director 126 4 504 5 2520 $35 $700 $88,200 

FLAS 

Language 

Instructor 1809 1 1809 0.5 905 $30 $15 $27,135 
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FRA 

Fellow 20 2 40 2 80 $50 $200 $4,000 

FRA 

Director 18 1 18 1 18 $40 $40 $720 

FRA 

Language 

Instructor 20 1 20 0.5 10 $30 $15 $300 

GPA 

Participant 

Annual 365 2 730 0.5 365 $35 $35 $12,775 

GPA 

Director 

Annual 16 2 32 6 192 $45 $540 $8,640 

GPA 

Participant 

Language 165 2 330 0.5 165 $20 $20 $3,300 

GPA 

Director 

Language 11 2 22 6 132 $45 $540 $5,940 

GPA 

Language 

Instructor 165 1 165 0.5 82.5 $30 $15 $2,475 

IIPP 1 2 2 6 12 $45 $540 $540 

IRS 30 2 60 5 300 $45 $450 $13,500 

LRC 15 2 30 7.5 225 $45 $675 $10,125 

NRC 127 2 254 12 3048 $45 $1,080 $137,160 

SA 

Participant 45 2 90 0.5 45 $35 $35 $1,575 

SA Admin 

Agency 6 1 6 2 12 $30 $60 $360 

SA 

Domestic 3 1 3 1 3 $30 $30 $90 

TICFIA 13 2 26 4 104 $45 $360 $4,680 

UISFL 35 2 70 10 700 $45 $900 $31,500 

TOTALS 5290 45 6754 13438 970 $501,585 

Refer to Attachment D for a chart of the current reporting schedule for grantees, to Attachment E for a spreadsheet 

outlining the proposed screens required for each report, and Attachment F for an overview of all proposed screens, 

indicating on which report(s) the screens appear and whether or not these are required.

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

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

other items, preparations for collecting information such as purchasing computers 

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

storage facilities.

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

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

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

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

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

comment process and use existing economic or regulatory impact analysis 

associated with the rulemaking containing the information collection, as 

appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory 

compliance with requirements not associated with the information collection, (3) 

for reasons other than to provide information or keep records for the government, 

or (4) as part of customary and usual business or private practices.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : $501,585

____________________

Total Annualized Costs Requested : $501,585

The total annual cost burden to respondents is shown in the Table in Item 12 above.

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 hourly wages of a GS-14, GS-13, and GS-12 education program specialists/management analysts 

and contractor support are used to estimate costs:

IEPS Staff Task Hourly 

Cost

Hours 

per 

Task

Number 

of

Reports

Total 

Hours 

for Task

Cost to 

Federal 

Government

Request OMB Clearance $51 200 1 200 $10,200 

Review AORC Performance 

Reports

$57 2 20 40 $2,280 

Review BIE Performance Reports $57 2 100 200 $11,400 

Review CIBE Performance Reports $44 2 66 132 $5,808 
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Review DDRA Fellow Performance 

Reports

$57 1.25 300 375 $21,375 

Review DDRA Institutional List $57 1 49 49 $2,793 

Review FLAS Student Performance 

Reports

$48 0.25 1809 452.25 $21,708 

Review FLAS Performance Reports $48 2 560 1120 $53,760 

Review FRA Institutional List $40 1 1809 1809 $72,360 

Review FRA Fellow Performance 

Reports

$40 1.25 40 50 $2,000 

Review GPA Institutional 

Performance Reports

$40 2.5 65 162.5 $6,500 

Review GPA Fellow Performance 

Reports

$40 0.5 200 100 $4,000 

Review IIPP Performance Reports $57 2 2 4 $228 

Review IRS Performance Reports $57 2 60 120 $6,840 

Review LRC Performance Reports $40 2 30 60 $2,400 

Review NRC Performance Reports $48 2 254 508 $24,384 

Review SA Domestic Agency 

Performance Reports

$40 0.5 3 1.5 $60 

Review SA Overseas Agency 

Report

$40 2 6 12 $480 

Review SA Fellow Performance 

Reports

$40 0.5 90 45 $1,800 

Review TICFIA Performance 

Reports

$40 2 26 52 $2,080 

Review UISFL Performance 

Reports

$57 2 70 140 $7,980 

Prepare New and Continuation 

Grant Awards Notifications 

$44 2 604 1208 $53,152 

Technical Assistance to Grantees $44 1200 $52,800 

Contractor Support $101 4000 $404,000 

Overhead $26,400 

Total $796,788 

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

Part 1 Form.

This is a revision of a currently approved collection. The changes in dollars reflect changes in wages 

since the previous collection. The overall burden hours decrease from 16,994 to 13,678. The previous 

burden hours included a student tracking component to Title VI programs which resulted in new screens 

and 1405 annualized new burden hours. The student tracking will be completed using another 

mechanism, so these screens have been removed from IRIS, resulting in decreased burden. We have 

also had a reduction in appropriations so there are fewer grantee respondents using the system. IFLE 

added Foreign Language Instructor screens to DDRA and FRA in order to collect data regarding program 

outcomes, and has removed the Foreign Language Self-Evaluation screens associated with these 

programs.

Program Previous 

Burden

Revised 

Burden Difference Reason Legislated

AORC 165 150 -15 program

BIE 1080 1000 -80 program
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CIBE 930 990 60 program

DDRA Fellow 600 300 -300 program

DDRA Director 196 196 0 program

DDRA Language 

Instructor 0 75 75 program

FLAS Fellow 1916 1809 -107 program

FLAS Director 2800 2520 -280 program

FLAS Language Instructor 958 904.5 -53.5 program

FLAS Student Tracking 1400 0 -1400 program

FRA Fellow 80 80 0 program

FRA Director 18 18 0 program

FRA Language Instructor 0 10 10 program

GPA Participant Annual 465 365 -100 program

GPA Director Annual 372 192 -180 program

GPA Participant 

Language 270 165 -105 program

GPA Director Language 216 132 -84 program

GPA Language Instructor 135 82.5 -52.5 program

IIPP 12 12 0 program

IIPP Student Tracking 5 0 -5 program

IRS 300 300 0 program

LRC 225 225 0 program

NRC 3504 3048 -456 program

SA Participant 142 45 -97 program

SA Admin Agency 18 12 -6 program

SA Domestic 3 3 0 program

TICFIA 104 104 0 program

UISFL 1080 700 -380 program

TOTALS 16994 13438 -3556

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.

IFLE does not plan to publish the information collection results.

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.

IFLE will display the OMB expiration date.
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18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

IFLE does not have exceptions to this statement.