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[ICR No. 1235.04] 1830-0564

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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

ICR No. 1235.04 and OMB Number: (XXXX) 1830-0564

Revised 05/20/2013

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 section. Please limit pasted text to no longer than 3 pages. 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.

This is a request to reinstate an information collection without change. 

The purpose of the information collection is to solicit applications for funding under the Native 

Hawaiian Career and Technical Education Program (NHCTEP) discretionary grant program. 

This program provides financial assistance to projects that offer career and technical education 

and related activities for the benefit of Native Hawaiians. Native Hawaiian community-based 

organizations are the only eligible applicants. 

The program is authorized by section 116 (h) of the Carl D. Perkins Career and Technical 

Education Act of 2006 (Public Law 109-270):

‘‘(h) NATIVE HAWAIIAN PROGRAMS.—From the funds reserved pursuant to section 

111(a)(1)(B)(ii), the Secretary shall award grants to or enter into contracts with 

community-based organizations primarily serving and representing Native Hawaiians to 

plan, conduct, and administer programs, or portions thereof, which are authorized by and 

consistent with the provisions of this section for the benefit of Native Hawaiians.”

On March 24, 2009, the Department published in the Federal Register a Notice of Final 

Requirements, Definitions, and Selection Criteria for the program. This notice---

 Clarified the programs and activities for which grant assistance may be used;

 Established requirements related to the payment of student stipends;

 Required applicants that do not propose to provide career and technical education directly 

to submit with their applications a written agreement with one or more entities that would 

be responsible for providing career and technical education with grant funds; 
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 Required grantees to support an independent evaluation of the effectiveness of their 

projects; and

 Established definitions, performance measures, and selection criteria for the program. 

https://www.federalregister.gov/articles/2009/03/24/E9-6441/native-hawaiian-career-andtechnical-education-program-nhctep-catalog-of-federal-domestic-assistance

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.

This information collection is for a notice inviting applications for a discretionary grant program. 

Information collected from applicants has been used, and will continue to be used, by the 

Department to evaluate the eligibility of an applicant for assistance and the extent to which 

activities for which the applicant seeks funding are allowable. Field reviewers have and will 

again evaluate the technical quality of the applications on the basis of applicants’ responses to 

the selection criteria identified in the notice. Department staff also have used and will continue 

to use the information to monitor grant recipient’s activities to ensure that funds are used only to 

carry out programs and activities set out in the approved application.

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.

Applicants will be required to submit their applications electronically through Grants.gov.

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.

There is no similar information available in other forms, or as the result of other information 

collections. This information collection does not duplicate any other information collection 

effort.

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.

Respondents are not small businesses.
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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.

The Department would not be able to award grant funds appropriated by Congress if this 

collection was not conducted. The frequency of collection is keyed to the appropriation 

cycle. 

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.

There are no special circumstances.

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 
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circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

A 30-day Federal Register notice will be published to give the public an opportunity to comment 

on this collection.

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

remuneration of contractors or grantees with meaningful justification.

No payments or gifts to respondents will be made.

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 authorizes the pledge of confidentiality should be provided.

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). If 

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 are no assurances of confidentiality. 

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.

There are no 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 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 
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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 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

We estimate that the Department will receive approximately 10 new applications from non-profit 

organizations. It is estimated that the applicants will spend 120 hours developing their grant 

applications, making the total respondent burden 1,200 hours. Based on the average preparation 

time of 120 hours per response, it is estimated that 100 hours would be used for review, research, 

and gathering information, with the remaining 20 hours used for typing, copying, and submission 

of the application.

Fiscal Year Estimated 

Number of 

Responses

Type of Staff Estimated 

Number of 

Burden 

Hours Per 

Response

Total 

Estimated 

Number of 

Burden 

Hours

2013 10 Professional

Clerical

 100

 20

 1000 

 200

TOTAL 10 120 1200

The estimated cost to respondents to develop applications, in response to the Notice Inviting 

Applications, is approximately $82,500 based upon an average hourly rate of $50.00 per 

professional and $25.00 per clerical. 

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 
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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:

The total for the capital and start-up cost components for this information collection is zero. The 

information collection will not require the purchase of any capital equipment nor create any startup costs. Computers and software used to complete this information collection are part of the 

respondents' customary and usual business or private practices, and therefore is not included in 

this estimate.

The total operation and maintenance and purchase of service components for this information is 

zero. The information collection will not create costs associated with generating, maintaining, 

and disclosing or providing the information that is not already identified in question 12 of this 

supporting statement.

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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The Federal costs are estimated to be approximately $70,624. This includes the salaries and 

expenses of program staff that manage the grants and other Department staff who assist with the 

grant competition. The method used to estimate the cost is as follows:

Program Office Staff:

1 GS-13 x 30 weeks = $ 59,724

TOTAL = $59,724

Other Department Staff = $ 900

Outside Review Cost = $ 10,000

 

TOTAL ESTIMATD FEDERAL COST = $70,624

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).

This data collection was discontinued in June 2010 as there were less than 10 applicants 

responding to FY 2010-2013 data collection years. There are no material, burden or respondent 

changes to this data collection. The Department is reinstating this data collection without 

changes; there is a program change increase of 1200 annual burden hours due to the increase of 

respondents from under 10 to 10, triggering the PRA and necessity to reinstate this discretionary 

grant application burden inventory.

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.

There are no plans to publish the information that will be collected.

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 is not seeking this approval.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.
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There are no exceptions to the referenced certification statement.