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EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable)

**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 hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review t ype of the collectio n (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The Department of Education is requesting an extension of the previousl y approved (Gaining Earl y Awareness and Readiness for Undergraduate Programs ) annual performance report that expires on January 31 , 201 3

. The information is collected under the authori ty of Title VII, Part A, Subpart 2, Section 711 of the Higher Education Act of 1965, as amended; the program regulations in 34 CFR 648; and the Education Department General Administrative Regulations (EDGAR) in 34 CFR 74.51 **. (Copies of the authorizing sta tute and the**  **program regulations are attached).** Further, the performance report form lends itself to the collection of quantifiable data needed to respond to the requirements of the Government Performance and Results Act (GPRA). Grantees are required to provide the data requested in order to obtain or retain benefit, according to 20 U.S.C. 1135, 34 CFR Sections 648.20, 648.31 and 648.66

. The overall goal of the program is to increase the number of low

- income students entering enrolled in a post

- secondary education. There are two versions of the performance report that are part of this package: the annual report. GEAR UP grants are awarded for a period of six and seven ye ars. Grantees are required to submit an annual performance report on April 15 for e ach budget period of the grant, and a final performance report 90 day s after the grant expires. The annual performance report asks for information specific to the budget y ear for which the report is being submitted. The final performance report asks for information specific to the last budget ye ar of the grant, and also requires the grantee to update the enrollment and graduation data of all students who have participated in a GEAR UP program at an y time during the project period. This information allows the Department to track the number of

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

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable) GEAR UP students who graduated and enrolled in postsecondary education during the grant period. 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 uses the data collected from the performance reports to: (a) monitor grantee compliance with program regulations (34 CFR 648) in administering gran t funds and selecting GAANN fellows; (b) collect the quantifiable data needed to evaluate project outcomes; and (c) assist in providing technical assistance to strengthen individual projects. The performance reports are used to collect programmatic data f or purposes of annual reporting, budget submissions to OMB, Congressional hearings, Congressional inquiries, and to respond to inquiries from higher education interest groups and the general public. 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 mean s of collection. Also describe any consideration given to using technology

to reduce burden. Grantees use a web

- based sy stem to electronically retrieve and submit the requested information in the performance report. The electronic version of the performance report automatically

saves grantee information and student level data entered in one y ear for use in the following ye ar. Therefore, the data does not need to be re

- entered, onl y updated when changes occur. This assists in reducing the burden to grantees, particularl y with regard to both the final report and the supplement to the final report, which require updates to the educational and employment status of all students that have been funded over the life of the grant. The supplement is due two y ears after the final report. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. Since the information submitted in th e performance reports is specific to the GEAR UP grant project, there is no duplication. There is no other collection instrument available to collect the information necessary to meet the purposes described in item 2 above. 5. If the collection of infor mation impacts small businesses or other small entities, describe an y methods used to minimize burden. A small entit y 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 op eration; (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 , count y, town, township, school district, or special district with a population of less than 50,000.3

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable) Learning Education Agencies (LEA) Institutions of H igher E ducation (IHE) are the sole recipients of GEAR UP grants. There is no impact on small businesses or small entities. 6. Describe th e consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. Collection of information is annual. Collection of information on a less frequent basis would impede the Department’s ability to determine if the grantee is making satisfactory progress in meeting the goals and objectives proposed in its initial application for funds. Further, failure to collect this information would hinder the Department’s ability to carry out its required responsibility to perform an overall assessment of the GEAR UP Program and its impact. 7. Explain any

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

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

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

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

 requiring respondents to retain records, other than health, medical, government contract, grant
- in

- aid, or tax records for more than three y ears;

 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 b y 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 unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or

 requ iring 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.4

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable) There are no special circumstances that would cause this information collection to be conducted in such a manner, except for the three

- ye ar record

- keeping retention period in EDGAR 74.53

. 8. As applicable, state that the Department has published the 60 and 3 0 Federal Register notices as required b y 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 b y 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 an y), 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 y ears
– 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. Comments and feedback regard ing the frequency , clarity of instructions, reporting format, and data elements included in the performance report have been received from grantee institutions in prior y ears . The feedback received was the impetus for the changes that have been incorporat ed into the performance report form in the past . The changes made in the for m since the last OMB submission are primarily for the purpose of streamlining and clarifying the intent of the questions. We published 60

- day and 30

- day

Federal Register Notices to allow public comment. For this submission, c larifying language was added to questions in the performance report to address previous input and comments received from grantees since the previous OMB submission

. No questions were added, on ly the languag e was clarified. There is no change in burden. The 60 day

Federal Register Notice was published in Vol. 77, page 24689 on 4/25/12. No public comments were received. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification

. The Department will not provide an y pa ym ents or gifts to respondents. 10. Describe an y 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 Sy stems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that5

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable) authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed suff icient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. There is no program regulatory requirement for assuring confidentiality , except as provided by EDGAR (34 CFR 75.740

– Privacy), and the Family Educational Rights and Privacy Act of 1974. Prior to accessing the web based reporting software there is a Pri vacy Act Notice that grantees must read. It states that the sy stem contains personal information protected under the provisions of the Privacy Act of 1974, 5 U.S.C. § 552a

-- as amended. Violations of the provisions of the Act may subject the offender to criminal penalties. A P rivacy Impact A ssessment was completed in 2009 with the previous submission and has been updated for the 2012 submission. We do not intend to do a system of records. A s ys tem of records has not been needed as we do not collect SSN information, and data is aggregated to evaluate the accomplishments and impact of the GEAR UP program as a whole . The records are destroy ed within three y ears of being received at the federal records center. 11. Provide additional justification for an y 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 wh y 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 an y steps to be taken to obtain their consent. This application does not include questions about sexual behavior and attitudes, religious beliefs, or other items that are commonl y considered sensitive and private. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for

- profit, private sector

– not
- for

- profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden ty pe: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to base hour burden estimates. Consultation with a s ample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widel y because of differences in activity , size, or complexity , show the range of estimated

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 a nd 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 P ersonally Identifiable Information, OM : 6

- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)6

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable)

hour burden, and explain the reasons for the variance. Generall y, 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 ROC IS IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of 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. The estimated total reporting burden for this data collection is 2,475 hours. This includes a total of 225 respondents (159 public institutions and 66 private institutions) , each with an estimated response time of 11 hours. The burden hours have not been reduced since the p revious collection package was submitted for clearance. Comments and feedback regarding the clarit y of instructions in the performance report have been received from grantee institutions. As noted under item 8, clarifying language was added to questions based on feedback received from grantees. The changes did not affect the burden hours. Affected Public (Estimated Burden Hours):

The burden to each individual respondent, established at 1 1 hours, is based on feedback from respondents during previous submissions. Estimated Cost to Respondents Ty pe of institution Public Private Number of institutions 159 66 Professional staff: 1 personnel x 8 hours x $35 $280 $280 Clerical staff: 1 clerical x 2 hours x $8 $16 $16 Total estimated cost per respondent $296 $296 Estimated costs to all respondents (# total respondents x $296) $47,064 $19,536 Total estimated costs to all respondents $66,600 Ty pe of institution Public Private Estimated number of respondents 159 66 Estimated preparation time Annual Report 11 hours 11 hours Average response time [(10.5x2) + 12]/3 = 11 hours 11 hours 11 hours Annual estimated burden hours 1,749 726 Total estimated burden hours for all respondents 2,47 5 hours7

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable)

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

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

- up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capit al 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 est imates are expected to vary widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate. In developing cost bur den estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60

- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is 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 co llection, (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 Cost s (O&M) :

____________________ Total Annualized Costs Requested : There are no other costs to the respondent except those that would be customary and usual business practices. 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.8

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable) Cost to Federal Government: Securing OMB approval once every three y ears (Review 15 hrs. x $45/per hour = $675 x 50% overhead = $338) $1,013 Other Departmental staff to review and approve the request (Review 5 hrs. x $55/per hour = $275 x 50% overhead = $138 $413 Estimated OMB review (Review 8 hrs. x $45/per hour = $360 x 50% overhead = $180) $540 Review of reports and analy sis of data (Review 120 hrs. x $45/per hour = $5,400 $5,400 Total estimate cost to government every three years $7,366 Annual cost to the Federal Government is $2,455. 15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result from re

- estimating burden and/or from economic phenomenon outside of an 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 materiall y 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 t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty

pe of collection (new, revision, extension, reinstatement with ch ange, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)

. No material changes were added to the report that would increase burden only clarifying language was added based upon comments and feedback from grantee institutions

. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. The information collected from the performance reports will be anal yz ed to determine if each grantee is meeting the approved goals and objectives for the project. Further, the information will be aggregated into a single program report and evaluated to de termine if the program as a whole is meeting its purpose. The aggregated data in the report will include demographic profiles of project participants, interim and final project outcomes (such as progress towards enrollment into post

- secondary education) , and program profiles of t ypes of services provided. The data will be reported at the conclusion of the six

- seven - ye ar grant period. Grants are scheduled to expire in the six or seventh ye ar of funding. Final reports are then due to the program office 90 day s after the expiration of the grant. Program staff will anal yz e the data for reporting in January . No complex analy tical or statistical techniques will be used.9

EDICS Tracking and OMB Number: ( 04846 ) 1840.0748v.5 Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable)
17. If seeking approval to not display the expiration date for OMB approval of the inf ormation collection, explain the reasons that display would be inappropriate. The Department will display on the form the expiration date for the OMB approval , as required. 18. Explain each exception to the certification statement identified in the Cer tification of Paperwork Reduction Act. There are no exceptions to the certification statement.