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ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13 **SUPPORTING STATEMENT**

**FOR PAPERWORK REDUCTION ACT SUBMISSION** FDMS Tracking and OMB Number: ED - 2013 - ICCD - 0014 1830 - 0542 

### 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 p rovide 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 purpose of this information collection is to reinstate In formation Collection approval for the Native American Career and Technical Educati on (NACTEP). The NACTEP program was approved under OMB Control Number 1830
- 0542. The Carl D. Perkins Career and Technical Education Improvement Act of 2006 (Act) (PL 109 - 270) (20 U.S.C.2301, et seq.), was signed into law on August 12, 2006. Section 116 (a)

– (g) of Perkins authorized the Native American Career and Technical Education Program. OVAE is planning to conduct a grant competition in the fiscal year (FY) 2013. Inthe Act, Congress has expanded and added elements to the statement of purpose, most significantl y by

s tating that, among other statutory purposes, programs should build on the efforts of States and localities to develop challenging academic and technical standards, and to assist students in meeting such standards, including student ac ademic achievement standards, especiall y in preparation for the high skill, high wage, or high demand occupations in emerging or established professions. (20 U.S.C. 2301 (1)) Congress has added to the statement of purpose the requirement that programs should provide technical assistance that promotes leadership, initial preparation, and professional development, improve the quality o f career and technical education teachers, faculty, principals, administrators, and counselors. (20 U.S.C. 2302 (5)) Additionally, the Act’s purpose section has been amended to include supporting partnerships among schools, postsecondary

institutions, baccalaureate degree granting institutions, area career technical centers, local workforce investment boards, business and indus try, professional associations, and intermediaries, as well as providing career and technical education students with opportunities throughout their lives, in conjunction with other education and training programs, to attain the knowledge and skills needed in this competitive National economy. (20 U.S.C. 2301 (6) and (7)) The collection of this information is necessary to make new awards with FY 2013 funds. The Office of Vocational and Adult Education (OVAE) is requesting the reinstatement of the OMB clearance under collection number 1830 - 0542 for the NACTEP documents and program requirements:2

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13 (a) Selection Criteria (b) Budget Instructions for NACTEP (including budget form and budget narrative) (c) Program Narrative (d) Guidelines for the Appeals Process (e) Supplemental Priorities for Discretionary Grants (f) Government Performance Results Act (GPRA Requirements) (g) Evaluation Requirements **2. I**  **ndicate 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 seeking to reinstate program specific components of the information collection under OMB Control Number 1830 - 0542. The previously approved collection was to award discretionary grants under Perkins III of 1998. Due to the reauthorization of Perkins IV, OVAE needs to conduct a new grant competition in FY 2013 for the NACTEP. The data collected on the application form will be used in various ways leading to th e award of a grant. F irst, enough information must be available to determine the eligibility of the applicant and to determine whether the project proposed can be funded under the provisions of the appropriate statutes or regulations. S econd, field reviewers use the information provided to rate the applications against published selection criteria. 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**  . NACTEP app l icants may submit applications electronically, via Grants.Gov, and OVAE estimates that approximately one - hundred percent of applicants will submit their applications, electronically . 4. **Describe efforts to identify duplication. Show specifically why any sim ilar**  **information already available cannot be used or modified for use for the purposes described in Item 2 above**  . The information requested does not exist elsewhere. 5. **If the collection of information impacts small businesses or other small entities, describ**  **e 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 ent erprise 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,**3

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13 **county, town, township, school district, or special district with a population of less than 50,000**  . Small businesses are not impacted b y this data 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** . The frequency

of collection is key

to the appropriation cycle. If the collection were conducted less frequentl y, eligible recipients would not be able to receive Federal funds to support Career and Technical Education programs. **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**  **fe wer 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 t**  **han 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 app**  **roved 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 imped**  **es 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 infor ma**  **tion’s confidentiality to the extent permitted by law** . No such circumstances exist. **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** 4

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13 **keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclos**  **ed, 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.**  This is a discretionary

grant program; the Department published a 30
- day Federal Register Notice seeking public comment. 9. **Explai n any decision to provide any payment or gift to respondents, other than**  **remuneration of contractors or grantees with meaningful justification**  . There are no pay

ments or gifts to respondents. 10. **Describe any assurance of confidentiality provided to responden ts 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 accorda nce**  **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, O MB 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 Inf ormation)**  **. 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 make s**  **no pledge about the confidenti ally 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 t heir consent**  . There are no questions of a sensitive nature. **12. Provide estimates of the hour burden of the collection of information. The**  **statement should:**5

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13
 **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 estima**  **tes. 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 expl**  **ain 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 t**  **he 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 f or**  **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 80 new applications for awards under NACTEP. Additionally, it is estimated that the applicants will spend 120 hours developing their grant applications, and the total respondent burden will b e 9,600 hours. Based on the average preparation time of 120 hours per response, it is estimated that 100 hours would be used for review, research, gathering information, etc. The remaining 20 hours would be used for typing, Xeroxing , and submission.

**Program Year**  **Estimated**

**Number of Responses**  **Type of Staff Estimated**  **Number of Burden**  **Hours Per Response**  **Total**

**Estimated Number of**  **Burden Hours**  2007 - 2008 80 Professional 100 8,0006

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13 Clerical 20 1,600

**TOTAL 80**  **1 20**  **9 ,600**  **ANNUAL AVERAGE**  **80 120**  **9,600**

 **Provide estimates**  **of annualized**  **cost to**  **respondents for**  **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.**  **I nstead,**  **this cost**  **should be**  **included in Item 14.** The estimated cost to respondents to develop applications, in response to the Notice Inviting Applications, is approximately $ 440,000 based upon an average hourl y rate of $ 50 .00 per professional and $ 25 .00 per clerical. **13. Provid**  **e 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 cost s 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 storag e 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 c**  **ontaining 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** 7

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13

**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**  **mon etization 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 start-up costs. Computers and software used to complete this information collection are part of the respondents’ customary and usual business or private practice s, and therefore is not included in this estimate. The total operation and maintenance and purchase of service components for this collection 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 fr om Items**  **12, 13, and 14 in a single table.** The Federal costs are estimated to be approximately $112,188. This includes the salaries and expenses of program staff that manage the grants and other Department staff to support the grant competition. The method used to estimate the cost is as follows: **Program Office Staff** 2 GS - 13 X 48 weeks = $39,168 **TOTAL** = $39,168 Other Department Staff = $25,020 Outside Review Costs = $48,000 **TOTAL ESTIMATED FEDERAL COST** = **$112,188** 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**8

ED - 2013 - ICCD - 0014 1830 - 0542 Revised: 02/11/13 **organic increase in the s ize 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 res pondent 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 cost s**  **(if applicable)** . There are no program changes or adjustments with this re
- instatement. 16. **For collections of information whose results will be published, out line 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, publica tion**  **dates, and other actions** . There are no plans for publication of data from this collection. 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**  . We are not seeking this approval. **18. Explain each exception to the certification statement identified in the Certification**  **of Paperwork Reduction Act.** There are no exceptions to the certification statement identified in the Certification of Paperwork Reduction Act.