SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT RENEWAL FOR 

STATES USING ALTERNATIVE POVERTY DATA TO REDISTRIBUTE TITLE I, 

PART A FUNDS TO LOCAL EDUCATIONAL AGENCIES WITH

FEWER THAN 20,000 TOTAL RESIDENTS (1810-0620)

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.

We are requesting a three-year extension of the current paperwork clearance package 

(OMB number 1810-0620) related to using alternative poverty data to redistribute Title I, 

Part A funds to local educational agencies (LEAs) with fewer than 20,000 total residents. 

This information package was last approved in 2008 and expires on November 30, 2011.

Sections 1124(a)(2)(B), 1124A(a)(4)(A), and 1125(d) of Title I, Part A of the Elementary

and Secondary Education Act, as amended by the No Child Left Behind Act, authorize State 

educational agencies (SEAs) to use alternative poverty data to redistribute Title I Basic, 

Concentration, and Targeted Grant allocations determined by the Department of Education 

(ED) to “small” local educational agencies (LEAs) with fewer than 20,000 total residents. 

(See http://www.ed.gov/policy/elsec/leg/esea02/107-110.pdf for the text of the relevant 

sections of the statute.) Section 200.74 of the Title I regulations further clarifies this 

provision by extending this flexibility to Educational Finance Incentive Grants. The statute 

requires SEAs to obtain approval of any alternative poverty measure they choose to use for 

this purpose. (See http://www.ed.gov/legislation/FedRegister/finrule/2002-4/120202a.pdf

for the text of §200.74 of the regulations concerning the use of an alternative method to 

distribute allocations to small LEAs.)

These statutory provisions have been part of the Title I, Part A statute since 1994. They

were first implemented in 1999 when ED switched to allocating Title I, Part A funds directly

to LEAs. 

Note that there is no collection of data by ED associated with these provisions in the statute 

and regulations. This narrative addresses only the burden associated with the actual process 

an SEA must follow to obtain approval from ED to use alternative poverty data to 

redistribute Title I, Part A funds to small LEAs. The burden connected with SEAs 

collecting alternative poverty data and using them to redistribute ED-determined allocations 

to small LEAs is addressed in the narrative of clearance package 1810-0622 concerning SEA

procedures for adjusting ED-determined allocations. 

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.
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In applying to ED for approval of the alternative poverty data selected, an SEA must 

identify the type of alternative data it proposes to use and assure that it has established a 

procedure through which a small LEA that is dissatisfied with the determination of its grant 

may appeal directly to the Secretary. As noted in item 1 above, this process is a 

continuation of procedures that have been in place since 1999. This narrative addresses the 

SEA burden connected with obtaining approval of the alternative data from ED. There is 

no requirement for an SEA to submit the alternative poverty data it chooses to ED. 

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 to adopt this means of collection. Also describe any consideration of using 

information technology to reduce burden.

The statute and regulations neither require nor preclude SEAs from using information 

technology to reduce burden. Most States have the data needed for this purpose available in 

an electronic form. States are not required to submit the alternative poverty data selected to 

ED.

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 duplication.

5. If the collection of information impacts small businesses or other small entities (Item 8b of 

IC Data Part 2), describe any methods used to minimize burden.

Small businesses are not affected by this data collection. The small entities that would be 

affected by the provision in the statute and regulations are small LEAs receiving Title I, 

Part A funds. Nationally, 10,399 (76 percent) of 13,628 LEAs nationally have a total 

resident population of less than 20,000. 

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.

This clearance package only addresses the burden to States that apply to ED for approval to 

use alternative data. There is no collection of data involved at the Federal level. SEAs 

must obtain approval from ED for the use of alternative poverty data in order to notify

LEAs of their final Title I, Part A allocations. To take advantage of this flexibility, an SEA

would need to collect the alternative poverty data at the State level in order to determine 
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small LEA eligibility and to redistribute Title I, Part A funds to those LEAs based on those 

alternative data. Failure to obtain permission from ED to use alternative poverty data 

would mean that SEAs could not take advantage of the flexibility available to them under 

sections 1124(a)(2)(B), 1124A(a)(4)(A), and 1125(d) of the statute and §200.74 of the 

regulations. Currently eleven States have chosen to use this flexibility. As many as 25 

States may use this flexibility. 

7. Explain any special circumstance 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 that 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 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.

The requirements in the statute and regulations are consistent with the guidelines in 5 

CFR 1320.5. None of the special circumstances outlined in the supporting statement 

instructions apply.

8. If applicable, provide a copy and identify the date and page number of publication in the 

FEDERAL REGISTER of the agency’s notice, 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.
4

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 public had the opportunity to comment on the burden during 60-and 30-day Federal 

Register Notices in August 2011 and October 2011. 

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

renumeration of contractors or grantees.

No payment is provided to respondents to apply for this flexibility.

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

assurance in statute, regulations, or agency policy.

Not applicable. The statute and regulations require no assurance 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. This 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.

The statute and regulations do not involve any questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. 

The estimated cost to the 25 SEA respondents that could seek approval from ED to use 

alternative poverty data for redistributing Title I, Part A funds to small LEAs is $6,000. 

This assumes that the additional time needed for the 25 States to develop their requests 

would total 200 hours at a cost of $30 per hour. (See the appendix for a more detailed 

breakout.) The approval for the use of alternative data would remain in effect for the 

duration of the current Title I authorization. 

Respondents Total Hours Total Annual Burden

25 8 200

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.)
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 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 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.

There are no startup costs.

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 cost to the Federal Government is estimated to be $1,200. This estimate is based on 

the possible need to develop and send out additional guidance and process requests from 

States seeking approval from ED for use of alternative poverty data. (See the appendix 

for a breakout of the estimated costs.)

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 

Form.

There are no program changes or adjustment to the current burden hours associated with 

sections 1124(a)(2)(B), 1124A(a)(4)(A). There are no burden hour increases or decreases 
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to the currently reported OMB inventory for this activity. 

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.

Not applicable, SEAs would be required to obtain approval of alternative data once during 

the reauthorization period. An SEA would be required to submit a new request to ED only

if it wished to change the alternative poverty measure used for redistributing Title I, Part A 

funds to its small LEAs.

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 proposed display of the OMB expiration date for data collection is not applicable 

because there is no information collected by ED. The SEA would collect and use any

alternative poverty data needed to redistribute Title I, Part A funds to its small LEAs. The 

SEA is not required to submit those data to ED. ED will display the OMB expiration date 

on any guidance issued concerning the use of alternative data. 

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

Paperwork Reduction Act.

There are no proposed exceptions to the certifications.

B. Collection of Information Employing Statistical Methods

There are no statistical methods.

SASA/BROWN/7/6/11/260-0976/Title I/Paperwork 2011//Alternative method narrative 2011

cc: OF/Hunkin/chron/State/writer
7

APPENDIX

ESTIMATE OF HOURS

Number of States 25

X Time needed for State to implement procedures for 

adjusting ED-determined allocations and make final Title 

I, Part A LEA allocations 

 8 hours

200

Total respondent hours 200 hours

X Cost rate $30

 

$6,000

Average burden hours per respondent

Person hours required nationally for States to develop requests 

to ED to use alternative poverty data for LEAs

with fewer than 20,000 total residents 200 hours

 Number of respondents 25

= Average burden hours per respondent 8 hours

Federal Level

Person hours 40

X Cost rate $30

$1,200