1 

### SUPPORTING STA

**TEMENT FOR PA** **PERWORK REDUCTION A CT 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 ad mi nistrative 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 g rant 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 curre nt 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 i n the Department of Education’s Visual Performa nce 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 me et this mandate. The development of IRIS made a fundamental change in how performance information and data for the fourteen IFLE programs, authorized under Title V I of the Higher Education Act and section 102(b)(6) of the Mutual Educational and Cultural Exchange Act, also known as Fulbright

Hays (F

- H), was collected. IFLE used this project to replace the paper collection instruments with an online performance reporting instrumen ts. Teams of IFLE staff as well as grantees have spent the past seven mo nths reviewing the instruments, ma king recommendations for cha nges, 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 com prehensive, and comparable than the traditional pape r reports. The reports provide IFLE ma nagem ent and program officers with valuable performance information to enable them to assess program effectiveness. The system also captures the data that is u sed for performance measurement

.2

This information collect ion 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 Busi ness 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 Sem inars 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 Regulation s (EDGAR), Part 74, section 74.51 and Part 75, sections 75.118, 75.253, 75.720. Note: I n 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 a re 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 i s 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 ma nagem ent uses the data and information generated from the system to inform the Title VI/F

- H program mon itoring, 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 s ystem) improvements. IFLE program officers use the system inform ation and data since they need reliable, comparable information about their grantees’ projects in order to determine whether grantees are completing grant

funded activities in compliance with the approved grant applications, and whether grantees are expend ing 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 s ystem 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 th e effectiveness of IFLE p rograms.3



### 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
- ma intained public web site. This is the fifth clearance of this reporting system so the use of a web

- based reporting syste m 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 s ystem 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 enti ties (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 ad mi nister these grant programs. The system greatly facilitates mu ch m ore 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;4



###  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 agenci es 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 exte nt 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, req uired 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 add ress 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.5

IFLE ma intains an ongoing dialogue with the constituency regarding the use, improvements, and enhancements of the IRIS reporting s ystem. Ma ny 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 im prove 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. Wepublish the applicable 60 and 3 0 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 payme nts 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 applica ble 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 q ualitative 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 adm inistrators at the FLAS, FRA, DDRA, and GPA grantee institutions upon creation of their IRIS reporting system account. W hen the grantee institutions submit the FLAS, FRA, DDRA, and GPA institutional lists, the IRIS reporting system will create a passwo rd 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. Sim ilarly, information in the NRC, IIPP, UISFL, BIE, CIBE, AORC, LRC, IRS, T I CFIA, 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 s ystem 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 expl anation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.6

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 estim ates 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 $27,1357

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 appea r 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,8



### 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 analysi s 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 complia nce 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 Ann ualized 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 Hourl**  **y 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 $5,8089

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. Wehave 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 colle ct 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 program10

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 collect ion 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.11



### 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.
IFLE does not have exceptions to th is statement.