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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 copy of the 

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

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

The Department of Education is requesting an extension of the previously approved (Gaining 

Early Awareness and Readiness for Undergraduate Programs) annual performance report that 

expires on January 31, 2013. The information is collected under the authority 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 statute 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 years. Grantees are 

required to submit an annual performance report on April 15 for each budget period of the 

grant, and a final performance report 90 days after the grant expires. The annual 

performance report asks for information specific to the budget year for which the report is 

being submitted. The final performance report asks for information specific to the last

budget year 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 any time 

during the project period. This information allows the Department to track the number of 

 

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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 grant 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 for 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 means of collection. Also describe any consideration given to using 

technology to reduce burden.

Grantees use a web-based system 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 year for use in 

the following year. Therefore, the data does not need to be re-entered, only updated when 

changes occur. This assists in reducing the burden to grantees, particularly 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 years after the final report.

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2 above.

Since the information submitted in the 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 information impacts small businesses or other small entities, describe any 

methods used to minimize burden. A small entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently

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

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.
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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 Higher Education (IHE) are the sole 

recipients of GEAR UP grants. There is no impact on small businesses or 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.

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 quarterly;

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

fewer than 30 days after receipt of it;

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

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

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

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

results than can be generalized to the universe of study;

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

approved by OMB;

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

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

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

agencies for compatible confidential use; or

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

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

the information’s confidentiality to the extent permitted by law.
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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-year record-keeping retention period in 

EDGAR 74.53.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to 

submission to OMB. Summarize public comments received in 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.

Comments and feedback regarding the frequency, clarity of instructions, reporting format, 

and data elements included in the performance report have been received from grantee 

institutions in prior years. The feedback received was the impetus for the changes that have 

been incorporated into the performance report form in the past. The changes made in the 

form 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, clarifying 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, only the language 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 payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

The Department will not provide any payments or gifts to respondents.

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

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 
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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.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

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 Privacy Act Notice that 

grantees must read. It states that the system 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 Privacy Impact 

Assessment 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 system 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 

destroyed within three years of being received at the federal records center. 

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.

This application does not include questions about sexual behavior and attitudes, religious 

beliefs, or other items that are commonly 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 type (federal government, 

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

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

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

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

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

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

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

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

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

 

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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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. Generally, estimates should 

not include burden hours for customary and usual business practices.

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

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

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

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

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

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

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

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

14.

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 

previous collection package was submitted for clearance. Comments and feedback regarding 

the clarity 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 11 hours, is based on feedback from 

respondents during previous submissions.

Estimated Cost to Respondents

Type 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

Type 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 2,475 hours
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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 system and technology acquisition, expected useful life of capital equipment, 

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

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

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

equipment; and acquiring and maintaining record storage facilities.

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

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

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

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

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

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

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

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

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and 

usual business or private practices. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

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.
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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 years

(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 analysis 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 any 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 materially changes a 

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

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

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

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

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

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 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.

The information collected from the performance reports will be analyzed 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 determine 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 types of services 

provided. 

The data will be reported at the conclusion of the six-seven-year grant period. Grants are 

scheduled to expire in the six or seventh year of funding. Final reports are then due to the 

program office 90 days after the expiration of the grant. Program staff will analyze the data 

for reporting in January. No complex analytical or statistical techniques will be used.
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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 information 

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 Certification of 

Paperwork Reduction Act.

There are no exceptions to the certification statement.