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OMB Number: 1840-NEW Revised: 11/18/2014

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 Office of Postsecondary Education (OPE) is seeking a new Office of Management 

and Budget (OMB) control number for the Campus Safety and Security Survey. The 

collection of information through the Campus Safety and Security Survey is necessary

pursuant to §485 of the Higher Education Act of 1965, as amended (HEA), with the goal 

of increasing transparency of college safety and security information for consumers. This 

collection is prompted by the changes made by the Violence Against Women 

Reauthorization Act of 2013 (VAWA) (Pub. L. 113.4) , that, among other provisions, 

amended §485(f) of the HEA also known as the Jeanne Clery Disclosure of Campus 

Security Policy and Campus Crime Statistics Act (Clery Act). Changes to the regulations 

in 34 CFR 668.46 were a result of negotiated rulemaking. This submission is for the 

2015-16, 2016-17, and 2017-18 collection years.

Section 485 of the HEA includes provisions designed to improve transparency in campus 

safety and security data for consumers. In response to these provisions, the Department 

of Education (ED) created the Web-based Campus Safety and Security Survey

(https://surveys.ope.ed.gov/security/) to collect data regarding campus safety and security 

and fire safety statistics by October 15th of each year. The data is then made available to 

the public on the Campus Safety and Security Data Analysis and Cutting Tool 

(http://ope.ed.gov/security/) and on College Navigator. This request is to collect campus 

crime data from institutions using the Campus Safety and Security Survey. 

The survey is a collection tool to compile annual data on campus crime and fire safety 

information. Because institutions are already required by Section §485 of the HEA to 

disclose most of this to ED in their annual security and fire safety reports, we estimate a 

minimal burden attached to the completion of the survey instrument.

 

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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

There are several sections to the Web-based Campus Safety and Security Survey. The 

first screen asks for general information of the individual who is completing the form on 

behalf of the institution. The following screen asks for general information about the 

Chief Administrative Officer, Campus Safety Officer, Campus Fire Safety Officer, and 

Title IX Coordinator. After the user completes these screens in the first collection year, 

the information will be prefilled for subsequent collections. Next, the user completes the 

Screening Questions. Based on the responses to the screening questions, the system will 

determine which data entry screens are relevant for the institution. The user will only

be prompted to complete the relevant screens, thereby reducing burden. Next, the user 

will enter crime, arrest, and disciplinary action statistics that their institutions have 

collected through the year. The final section of the survey asks institutions to provide 

information about each fire reported to have occurred within an on-campus student 

housing facility. 

Section 485(f) of the HEA, which mandates the collection of campus safety and security 

information, requires ED to collect safety and security statistics from institutions 

participating in the federal student financial programs authorized by title IV of the HEA 

and to make the statistics available to the public. Foreign institutions of higher 

education are exempt from this requirement. Section 485(i) of the HEA requires ED to 

collect fire safety statistics from eligible institutions and make them available to the 

public. 

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 required information is collected using the Annual Security Report and reported to 

ED using the Campus Safety and Security Survey that is then posted to ED’s web page. 

The Campus Safety and Security Data Analysis Cutting Tool allows interested parties 

access to data regarding one or more institutions or data that has been aggregated. This 

provides interested parties information to raise awareness of campus security issues at a 

given institution. ED also makes the data available on College Navigator. This 

information is also used in program compliance efforts and institutional reviews.

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. 

On an annual basis institutions electronically report their campus crime and fire safety 

statistics via ED’s Campus Safety and Security Survey website. Institutions use the 

information they have already collected for their annual security and fire safety reports to 
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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

report information to ED. The use of this electronic method of transmission allows for 

accuracy in the reporting of the information to ED by institutions, minimizing 

transcription error by multiple parties. The use of the electronic method also employs 

skip logic, reducing burden for institutions.

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.

OPE has contacted the National Center for Education Statistics to determine if any 

overlap exists between the Campus Safety and Security Survey and their School Survey 

on Crime and Safety (SSOCS) in cases where postsecondary and secondary statuses may 

overlap. During that consultation, ED determined that SSOCS is a sample survey that 

provides industry estimates and does not list individual institutional data. The Campus 

Safety and Security Survey is a compliance collection and does show statistics at the 

institutional level. No duplication exists between these collections within ED.

ED has also reached out to the Department of Justice (DOJ) to confirm that no overlap 

exists with any of their data collections. While the DOJ is working to develop a climate 

survey on rape/sexual assault on college campuses, their climate survey is a small pilot 

study focused exclusively on rape, and DOJ may not elect to move to a national sample. 

As a result, we have determined that there is very little, if any, overlap with DOJ 

collections.

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.

No small businesses are affected by this information collection.

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.

Annual campus safety and security data collection is required by the HEA. Without the 

Campus Safety and Security Survey, ED would not meet its legal obligation to make this 

data available to the public.
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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

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.

The collection of this information will continue to be conducted in a manner that is consistent 

with the guidelines in 5 CFR 1320.5(d)(2). 

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 
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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

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.

ED has published the applicable 60 and 30 day notices in the Federal Register inviting 

public comment on the form and the burden assessment. This is the 30 day notice. ED 

received only one substantive comment on the survey during the 60 day period. This 

comment pointed out a slight discrepancy between a table’s heading and the text within 

the table, and as a result, ED changed the text within the table on page 30 of the survey to 

read “total occurrences reported by police” instead of “total occurrences reported to 

police.” There is no expected change in burden associated with this change. The Office 

of the Vice President and the Department of Justice also gave feedback during the 

regulatory clearance process.

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

of contractors or grantees with meaningful justification.

There are no payments or gifts offered 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 

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.

ED makes no pledge about the confidentiality of the data.

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.

 

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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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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

This collection contains 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 

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.

Based on 2014 data there are 7,135 institutions that would be required to report to the 

Campus Safety and Security Survey system. This figure includes 1,990 Public, 1,851 

Private Not-for-Profit, and 3,294 Private For-Profit institutions. We estimate that it 

would take an institution approximately 25 minutes to complete the form, since 

institutions should have these numbers readily available after releasing their annual crime 

and fire safety reports. 

Estimated annual burden to respondents 
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OMB Number: 1840-NEW Revised: 11/18/2014

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 

Current Burden: 

Respondent/

Responses

Hours/Response Hours of Burden

Proposed Burden

 0 0

For-Profit Institutions

Web-based Campus Safety and 

Security Survey

3,294 x .42 = 1,383

Not-For-Profit Institutions

Web-based Campus Safety and 

Security Survey

1,851 x .42 = 777

Public Institutions

Web-based Campus Safety and 

Security Survey

1,990 x .42 = 836

Total Respondent/Responses 7,135 Total Hours of Burden 2,996
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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

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 capital/startup costs to respondents.

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.

On an annual basis, over three collection years, ED’s contract costs will average about 

$1,600,000 a year. This cost is associated with the contract awarded to conduct the data 

collection and includes the preparation and dissemination of “reminder” data collection 

memos to over 7,000 institutions of higher education. Throughout the collection period, 

the contractor is responsible for oversight of the individual submissions, including daily 

reviews of the data submitted for errors or inconsistencies that could not be detected by 

the online application and the reviewer must also read the text to determine if the 

response is adequate and appropriate; follow up on any questions posed by institutions 

submitting, and data migration. The contract also staff a help desk 8 am to 6 pm on 

business days.

The cost for ED staff to review the data collection is based on the hourly salary of a GS 

12-5. Staff will take approximately 40 hours to review the data at a yearly cost of 

$1,643.

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).
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OMB Number: 1840-NEW Revised: 11/18/2014

RIN Number: XXXX-XXXX (if applicable)

This is a request for a new OMB collection. The increase in burden of 2,996 hours is 

based on the survey collection form designed to include information regarding the crimes 

that the Violence Against Women Reauthorization Act of 2013 added to the Clery data 

collection and dissemination requirements. Furthermore, as a result of the public 

comment process and consultation with other Federal agencies, ED has elected to collect 

information regarding the number of crimes which are unfounded as well as the contact 

information of certain institutional administrators.

ED estimates that it will take approximately 25 minutes for each of the institutions to 

provide the relevant information on the form. This is based on administrators already 

having calculated and disclosed the crime statistics in their annual security and fire safety 

reports. 

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.

Both institutions and ED display the annual campus safety and security survey results on 

web sites to comply with regulation and statute, as well as to offer greater information 

sharing with the public. 

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.

ED is not seeking approval to forego displaying the OMB approval expiration date.

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

Paperwork Reduction Act.

ED is not seeking exceptions to the certification statement.