SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

INVESTING IN INNOVATION (i3) GRANT PROGRAM

Justification:

1. Explain the circumstances that make the collection of information necessary.

The Investing in Innovation (i3) Fund was established under section 14007 of the 

American Recovery and Reinvestment Act of 2009 (ARRA). Since this is a 

competitive program, the Department needs to collect applications in order to 

determine which eligible applicants should receive a grant award. The Department 

will make three types of awards under this program: Scale-up Grants, Validation

Grants, and Development Grants. These grants will provide funding to support local 

educational agencies (LEAs), and nonprofit organizations in partnership with one or 

more LEAs or a consortium of schools to apply for funding to expand and develop 

innovate practices that can serve as models of best practices, (2) allow eligible entities 

to work in partnership with the private sector and the philanthropic community, and 

(3) identify and document best practices that can be shared and taken to scale based 

on demonstrated success. 

2. Indicate how, by whom, and for what purpose the information is to be used.

The information provided in the application will allow field readers and the 

Department of Education to determine if applicants are eligible and identify which 

applications qualify for funding. An additional part of the application consists of 

assurances regarding the applicant's compliance with applicable Federal laws and 

regulation in 34 CFR 76.132.

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.

Applicants are required to submit applications electronically to the U.S. Department 

of Education. All applicants are currently required to submit their applications 

electronically through Grants.gov. 

4. Describe efforts to identify duplication. 

The information supplied by the applicant is not contained in any other data 

collection, and is unique to this program and the particular grantee. The application is 

a single document intended to serve a specific authorized purpose, and is in keeping 

with statutory requirements in 34 CFR 75.100.
5. If the collection of information impacts small businesses or other small entities, 

describe any methods used to minimize burden.

Small businesses and other small entities are not impacted by this data collection.

6. Describe the consequences to Federal program or policy activities if the 

collection is not conducted or is conducted less frequently

The Department cannot distribute these grant awards to recipients without an 

application requesting the funds. If no application information were collected, the 

Department would not know which organizations want or merit funding.

7. Explain any special circumstance that would cause an information collection to 

be conducted in a manner inconsistent with 5 CFR 1320.5.

There are no special circumstances that require the collection to be conducted in a 

manner inconsistent with the guidelines in 5 CFR 1320.5.

8. 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.

The Department has consulted with potential applicants, other interested 

organizations and entities to obtain their views on the availability of possible 

requested information and potential application processes for these grants. In 

addition, on December 14, 2012, the Department published a Federal Register notice 

requesting public comment on the proposed requirements, definitions, priorities, and 

selection criteria for this program and incorporated such feedback into the 

competition’s final requirements, which were published in the Federal Register on 

March 27, 2013.

 

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

remuneration of contractors or grantees.

No gifts or payments will be made to application respondents other than the award to 

the grant recipient.

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

for the assurance in statute, regulations, or agency policy.
No assurance of confidentiality is provided to respondents except as it’s provided by

the Privacy Act of 1974 and the Department of Education’s policies governing the 

review of Discretionary grant application as found in the Department of Education's 

Privacy Act Regulations 34 CFR Part 5b. 

11. Provide additional justification for any questions of a sensitive nature

There is no question of sensitive nature in this collection of information.

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

We estimate that a total of approximately 1450 applications will be submitted each 

year for the i3 grant competitions. This is based on the number of applications that 

we received in the most recent i3 competitions and also takes into account i3’s new 

Development pre-application process that we implemented in FY 2012. 

The Development pre-application process resulted in an increase in the number of 

applications received but it ultimately decreased the net burden for all respondents.

The following chart details the estimated burden for all i3 grant types, Development 

pre-application, Development full application, Validation, and Scale-up, which equals 

66,000 hours. 

Estimated Hours of Burden and Cost of the Collection of Information

Application 

Type

Hours per 

Application

Cost per 

Application

Number of 

Applications

Respondent 

Cost per 

Application

Total 

Hours

Total Cost

Development 

PreApplication

30 $25.00 1000 $750.00 30,000 $750,000.00

Development 

Full 

Application

60 $25.00 300 $1,500.00 18,000 450,000.00

Validation 120 $25.00 100 $3,000.00 12,000 300,000.00

Scale-up 120 $25.00 50 $3,000.00 6,000 150,000.00

Totals 1450 66,000 $1,650,000.00

Previous 

Totals 2200 117,000 $2,925,000.00
13. Provide an estimate of the total annual cost burden to respondents or record 

keepers resulting from the collection of information. 

Annual Costs to Respondents (capital/start-up, and operation and maintenance): The 

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

zero. This information collection will not require the purchase of any capital 

equipment nor create any startup costs. 

14. Estimated annualized Federal cost:

Cost to Federal Government: 

Cost for Federally-supervised review of 

applications

Processing applications – staff

(8 staff x 120 hours x $48 per hours=$46,080)

(Overhead cost: $46,080 x 50 percent = $23,040) $69,120.00 

Contractor logistical support for application 

processing, field reading, and preparing 

notifications for successful and unsuccessful 

applicants for all i3 competitions $1,000,000.00 

Staff time for conducting peer review.

(4 weeks x 95 review panels, each with a staff 

person as panel chair)

(95 staff x 160 hours x $48 per hour=$729,600)

(Overhead cost: $729,600 x 50 percent=$364,800) $1,094,400.00 

Staff time for generating slate

(3 staff x $48 x 32 hours=$4608)

(Overhead cost: $4608 x 50 percent = $2304) $6,912.00 
Staff time to review and approve funding 

recommendations

(8 hours per grant award x 25 awards)

(25 awards x 8 hours per award x $48 per hour 

= $9600

(Overhead cost: $9600 x 50 per cent = $4800)

$14,400.00 

Staff time to generate, approve, and issue grant 

awards

(2 hours per award x 25 awards= 50 hours)

($48 per hr x 50 hours = $2400)

(Overhead cost: $2400 x 50 percent = $1200) $3,600.00 

Total estimate cost to government (competitive 

year) $2,188,432.00 

15. Explain the reasons for any program changes or adjustments reported in Items 

13 or 14

We estimate that a total of approximately 1450 applications will be submitted each 

year for the i3 grant competitions. This is a decrease from the estimate of 2200 

applications in our current information collection. The new estimate is based on the 

number of applications that we received in the most recent i3 competitions. The new 

estimate also takes into account several changes in i3’s application process in an 

effort to streamline the application process. 

First, in FY 2012, i3 implemented a pre-application process for the Development

competition. In previous competitions, many more Development applicants 

completed the full application than were competitive for funding as judged by their 

peer review scores. Given that the pre-application and its accompanying documents 

are substantially shorter than the full application, using a pre-application reduces the 

burden on prospective applicants. For future competitions, all applicants under the i3 

Development grant competition will submit a pre-application. 

We anticipate an increase in the number of respondents as a result; however, we 

anticipate a decrease in the overall burden on applicants. Following the initial 

review process, only entities that have submitted pre-applications that are scored 

highly by the peer reviewers will be invited to submit full applications, though other 

pre-applicants may submit full applications if they wish. We do not anticipate many 

pre-applicants who were not highly scored to submit full applications. Based upon 

the small number of full applications that are expected, we anticipate a significant 
decrease in the cumulative number of burden hours on applicants to the i3 

competitions. 

Additionally the program will change the method by which applicants submit the 

Applicant Information Sheet for all of the i3 competitions. Currently, applicants are 

asked to go to the program website and complete a fillable .PDF, save it, and upload 

to the grants.gov system for submission. Applicants will still be asked to upload the 

.PDF that is generated to grants.gov, however, the survey will be hosted on a 

Website managed by our contractor. The proposed change will be easier for 

applicants to complete and submit as part of their application, and will allow data to 

be collected through an online survey tool thus making data capture easier for the 

program as well. 

Finally, the program has added two eligibility checklists for Scale-up, Validation, and 

Development full applications. Each applicant will complete only one of the two 

forms, depending on the type of applicant. Each applicant will use the form to

indicate that they have met the i3 statutory requirements and to give the page numbers 

where the supporting information can be found within the application. The addition 

of these forms will not have an impact on the burden for the applicants, but will 

facilitate the review process for the field readers and the Department.

These changes will reduce the total number of burden hours for applications to the i3 

competitions from 117,000 to 66,000 hours as explained in the chart in item 12 

above.

16. For collections of information whose results will be published, outline plans for 

tabulation and publication.

The Department will make the following available to the public on the Department’s i3 

Web site: 

 A list of all applicants and their partners; the type of grant for which the 

applicant applied; and the requested budget, including the amount of funds 

requested for each partner; 

 All Scale-up applications with personally identifiable information and 

proprietary information identified by the applicant redacted; 

 All successful Validation and Development applications with personally 

identifiable information and proprietary information identified by the 

applicant redacted; and 

 Peer reviewer scores and comments (Technical Review Forms) for all 

successful applications. 

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 expiration date will be displayed on the information collection.
18. Explain each exception to the certification statement identified in Item 20, 

"Certification for Paperwork Reduction Act Submissions form”

There is no exception to the “Certification for Paperwork Reduction Act 

Submissions”