ICRAS ICR ID and OMB Number: (1974.01) XXXX-XXXX

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

FOR PAPERWORK REDUCTION ACT 

SUBMISSION

Highly Qualified Teacher Collection through EDFacts

September 2013

SUPPORTING STATEMENT, PART A: 

JUSTIFICATION

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ICRAS ICR ID and OMB Number: (1974.01) XXXX-XXXX

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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.

The Fiscal Year 2013 Continuing Resolution (CR) directed the Department of Education 

(ED) to submit a report to Congress by December 31, 2013, on the extent to which 

students with disabilities, English Learners, students in rural areas, and students from 

low-income families are taught by teachers who are deemed to be Highly Qualified 

Teachers (HQT) while currently enrolled in an alternative route to certification program. 

The exact language of the requirement is found in Section 145(b) of H.J. Res. 117 as 

follows:

“(c) Not later than December 31, 2013, the Secretary of Education shall submit a 

report to the Committees on Appropriations and Health, Education, Labor, and Pensions 

of the Senate and the Committees on Appropriations and Education and the Workforce of 

the House of Representatives, using data required under existing law (section 

1111(h)(6)(A) of Public Law 107–110) by State and each local educational agency, 

regarding the extent to which students in the following categories are taught by teachers 

who are deemed highly qualified pursuant to 34 C.F.R. 200.56(a)(2)(ii) as published in 

the Federal Register on December 2, 2002:

(1) Students with disabilities.

(2) English Learners.

(3) Students in rural areas.

(4) Students from low-income families.”

However, the cited provision (section 1111(h)(6)(A) of Public Law 107-110), does not 

require state educational agencies (SEAs) or local educational agencies (LEAs) to 

maintain the required information in a format suitable for rapid and simple reporting to 

ED, and we understand that few SEAs or LEAs have data systems capable of doing so. 

In order to be responsive to the statutory provision, ED investigated the least burdensome 

method by which to collect and report the required data, or reasonable alternatives. To 

respond to the statutory requirement, a new data collection will be needed from all SEAs. 

ED is requesting a new OMB control number for the HQT CR collection. 
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RIN Number: XXXX-XXXX (if applicable)

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.

These data will be used to prepare a report for Congress to respond to the CR 

requirement. 

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.

ED seeks approval from the Office of Management and Budget (OMB) under the 

Paperwork Reduction Act of 1995 (PRA) to collect the SY 2013-14 data outlined in 

Attachment B. In order to reduce burden on SEAs and maximize the availability and 

utility of the data, ED plans to collect these data through EDFacts, which is a proven data 

collection system that allows availability and utility of the data for programs across ED. 

EDFacts is an ED initiative to put performance data at the center of ED’s policy, 

management, and budget decision-making processes for all K-12 educational programs. 

EDFacts provides an electronic submission system for SEAs, and centralizes the 

availability of the performance data supplied by SEAs to enable better analysis and use in 

policy development, planning, and management. 

The requirement to submit through EDFacts is in line with Final Regulations amending 

34 C.F.R. Part 76 and published in the Federal Register on January 25, 2007, in which 

the Secretary required that States submit their performance reports, financial reports, and 

any other required reports, in the manner prescribed by the Secretary, including through 

electronic submission, if the Secretary has obtained approval from OMB under the PRA. 

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 Question 2 above.

A thorough analysis of the current EDFacts and current Civil Rights data collections 

indicate that these data are not currently collected from the universe of state and local 

educational agencies, nor can they be derived from any data currently collected. Note 

that the EDFacts IC package (1875-0240) includes a count of special education teachers 

who are highly qualified (in full-time equivalencies) taken on or about the state IDEA 

Child Count date. However, the SY 2013-14 data are due in November 2014 and are not 

at the level of detail needed for this collection, so the submission for IDEA purposes 

cannot be used for the purposes described in Question 2. 
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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.

This collection will not impact small businesses or other small entities as defined above.

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.

These data are needed to respond to the statutory reporting requirement. 

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.

This information collection activity does not have special circumstances that would 

include any of the requirements listed above.

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 
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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.

The proposed collection was designed to be the most practical and least burdensome 

approach to respond to the data reporting requirement in the CR. Based on information 

available through the monitoring activities of Statewide Longitudinal Data Systems 

grant program on state capacity around reporting teacher-related data, and interviews 

conducted with nine states, ED concluded that using the teacher as the unit of analysis in 

the data collection would be far less burdensome on respondents than using the student 

as the unit of analysis, which would have been the necessary approach for meeting the 

specific reporting requirement in the CR. If ED were to use the student as the unit of 

analysis, most respondents would not have the necessary linkages in their student and 

teacher data systems to report the data using the student as the unit of analysis. By using 

teachers as the unit of analysis, ED will be able to minimize the burden on SEAs and 

determine the extent to which English language learner (ELL) students, students in rural 

areas, special education students and students from low-income families are taught by 

teachers deemed highly qualified but who have not yet completed their alternative route 

to certification program. A 60-day and 30-day comment period will be provided for this 

collection in order to obtain additional information from SEAs as to the availability and 

burden associated with the proposed collection. 

In order to meet reporting requirements on rural areas and low-income families, ED will 

utilize data already collected within EDFacts to approximate the percent of each district 

represented by those demographic categories. These percentages will be applied to the 

reported count of all teachers and count of all highly qualified teachers enrolled in an 

alternative route to certification program for use in the resulting report for Congress.

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

remuneration of contractors or grantees with meaningful justification.

There is no current remuneration for any respondent. 
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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 A108 – 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.

None of the data proposed for collection are personally identifiable information (PII). 

There has been no assurance of confidentiality provided to the respondents

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, such as sexual behavior and attitudes, 

religious beliefs, and other matters that are commonly considered 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 Question

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 hour burden, and explain the reasons 
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RIN Number: XXXX-XXXX (if applicable)

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 Question 14.

Respondents: 53 SEAs are the primary respondents (50 states, District of Columbia, 

Puerto Rico, and the Bureau of Indian Education). A small number of states have one 

system from which they can extract all of the data for this collection. However, in 

most states and for the large majority of the approximately 17,000 LEAs in the 

country, the LEAs will need to respond to this collection by reporting new data up to 

the SEA. For the purpose of this estimate, all 53 SEAs and 17,000 LEAs were 

included in the cost estimate. 

Average hours required per SEA respondent: 321 to gather data from either LEAs or 

from disparate SEA systems, validate the data, prepare data files, and submit to ED.

Average hours required per LEA respondent (to SEAs): 6

Total hours for collection: 115,000

Average wage rate: $50.00

Total annualized cost: $5,750,000

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 Questions 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 
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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 Question 12.

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

The collection of EDFacts data for the foreseeable future will require no additional 

systems development efforts by SEAs. SEAs are currently involved in the development 

of State education information systems for their own use and for reports in response to 

education legislation. The guidance, standards, and best practices developed by EDFacts 

have been noted by the SEAs as helping them reduce the total costs associated with those 

systems development activities by providing cost effective common education 

information management solutions to SEAs and LEAs. Some of this work is being done 

under the Institute of Education Sciences (IES) discretionary grants made available to 

help SEAs develop longitudinal statewide education data systems.

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 Questions 12, 13, and 14 in a single table.

The estimated cost to ED is approximately $200,000 for collection and data cleansing 

(including follow-up and resolution support in the event of data anomalies) and $175,000 

for the report preparation. 

15. Explain the reasons for any program changes or adjustments. Generally, 

adjustments in burden result from re-estimating burden and/or from economic 
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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 is a new collection request necessitated by the FY 2013 Continuing Resolution 

language referenced in the response to Question 1.

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. 

ED will prepare a summary report for Congress based upon the data collected from the 

SEAs. 

17. 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.

Date Action

February 2014  Anticipated OMB clearance of final collection.

March 2014  Enable EDFacts system to accept data

June 2014  Due date for SEAs to report approved HQT data

(June 1)

 Preliminary data review

June /July 2014  Data file prepared and data tables generated

August/September 2014  1

st draft of report reviewed by ED offices and 

revised based on comments

 2

nd review cycle

November 2014  3

rd and final draft prepared and transmitted to 

Congress

18. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

This collection will display the OMB approval date in all transmittal documents 

requesting the information from the state or local agencies and in any written discussion 
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or representation of the collection. The OMB number will be properly displayed on the

EDFacts file specification documents.

19. Explain each exception to the certification statement identified in the Certification 

of Paperwork Reduction Act.

ED is requesting no exemptions from the Certification.