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ED-2013-ICCD-0014 1830-0542 

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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 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 purpose of this information collection is to reinstate Information Collection approval 

for the Native American Career and Technical Education (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. 

In the Act, Congress has expanded and added elements to the statement of purpose, most 

significantly by stating 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 academic 

achievement standards, especially 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 of 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 industry, 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: 
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(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. 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.

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 the 

award of a grant. First, 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. Second, 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 applicants 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 similar 

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, 

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 notfor-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, 
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county, town, township, school district, or special district with a population of less 

than 50,000.

Small businesses 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, 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 frequently, 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 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.

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 
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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.

This is a discretionary grant program; the Department published a 30-day Federal 

Register Notice seeking public comment. 

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 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. 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 A130 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.

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 their consent.

There are no questions of a sensitive nature.

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

statement should:
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 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.

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 be 

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 8,000 
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Clerical 20

 

 1,600

TOTAL 80 120 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. Instead, 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 hourly rate 

 of $50.00 per professional and $25.00 per clerical. 

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 
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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 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 practices, 

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 from 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 
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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).

There are no program changes or adjustments with this re-instatement. 

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.

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.