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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

EDICS Tracking and OMB Number: (XXXX) 1810-0614 v 18

Revised 01/27/2012

RIN Number: N/A

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 Consolidated State Performance Report (CSPR) is the required annual reporting tool 

for of each State, the Bureau of Indian Education, District of Columbia, and Puerto Rico 

as authorized under Section 93031of the Elementary and Secondary Education Act 

(ESEA), as amended. The CSPR consists of two parts. Part I of the CSPR collects data 

related to the five ESEA goals established in the approved June 2002 Consolidated State 

Application, information required for the Annual State Report to the Secretary, as 

described in section 1111(h)(4) of ESEA, and data required for the Homeless Collection. 

Part II of the CSPR collects information related to state activities and outcomes of 

specific ESEA programs needed for the programs’ GPRA indicators or other assessment 

and reporting requirement.

This submission requests to renew the currently-approved CSPR collection (OMB 1810-

0614). There are no changes between this collection and the previously approved

collection.

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.

In general, the Department uses the information derived from the CSPR to: (1) monitor 

and report its progress in meeting Strategic Plan goals; (2) assess and report individual 

program performance; (3) monitor States’ implementation of the ESEA and the extent to 

which States are meeting program and accountability goals; (4) identify areas for 

technical assistance to States and overall program improvement; (5) inform policy and 

program improvement; and (6) inform other reporting and program evaluation 

requirements. 
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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

The program office will use the information to monitor compliance and to obtain a clear 

understanding of the needs of States to inform program office technical assistance 

initiatives. 

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.

All responses are collected electronically via the EDEN submission system. Over 70% of 

responses are populated with data from EDFacts. The EDFacts System allows each State 

Education Agency (SEA) to provide the EDFacts data in the most automated, electronic 

format that the technology of that specific SEA can currently support. Provisions were 

made to receive data in multiple formats to ensure the least possible burden on each of 

the participants. 

The remainder of the questions are considered “manual entry” and values are entered into 

fields in the EDEN submission tool. Once states have completed their submission, they

electronically certify that it is accurate.

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.

In order to reduce duplication of information, many of the questions in the CSPR are prepopulated with data from EDFacts. 

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, 

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

than 50,000.

Small businesses or other small entities are not impacted.

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 proposed data collection includes information necessary for a report to Congress that 

is required to be submitted on an annual basis and GPRA data that is required to be 

collected for multiple grant programs. If the information is not collected, data on key

aspects of elementary and secondary education programs will not be available. 
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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

Consequently, the Department would be unable to meet statutory and regulatory

requirements for collection and reporting of data on grantees’ activities and outcomes.

The information collected is used to provide data on education to the public through 

websites, such as ED Data Express, one of the Department’s initiatives under the 

Department’s Open Government Plan, and ad-hoc reports for education researchers. Data 

informs monitoring and technical assistance efforts.

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 special circumstances exist that would cause the information collection to be 

conducted under any of the circumstances described above.

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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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

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.

Individual program offices and principal offices consult with State officials, SEA 

leadership, and CSPR and EDFacts coordinators on their information collections. 

Consultations occur through ongoing program monitoring and technical assistance, 

program related conferences, data conferences, Webinars and teleconferences, which 

enable ED to ascertain the availability and quality of the required data. 

In addition, ED published a 60-day Federal Register Notice to solicit comment from the 

public and we will publish a 30-day Federal Register Notice to give the public an 

additional chance to comment.

ED received comments from states during the 60-day comment period and has provided 

responses in an attached document. 

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

remuneration of contractors or grantees with meaningful justification.

No payment or gift of any kind will be provided 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.

Data collection through the CSPR are aggregate, not about individual students, but they

are protected in accordance with the requirements of the Family Educational Rights and 

Privacy Act (FERPA). As a matter of policy ED assures respondents that in reporting 
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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

data to the public, no n-size will be used that can readily identify sensitive information 

about individuals, alone or in combination with other data. The n-size used to redact 

values below which individual students could be identified is based on a methodology

developed by the National Center for Education Statistics, and it is used in combination 

with other privacy protection methodology to ensure compliance with FERPA. 

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.

The information collection does not include questions of a sensitive nature, such as 

sexual behavior and attitudes, religious beliefs, and other matters that are commonly

considered private. The education data collected will only consist of information about 

states, school districts, and schools.

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.
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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

Previously, the total annual reporting and recordkeeping burden for the SY 2013-14 

CSPR collection was estimated to be 11,687. The annual burden to each of 53 SEA 

respondents for the CSPR collection was estimated to be 34.34 hours. The burden will 

stay the same for the SY2014-15 collection. The combined burden to States for this 

information collection will be 1,740.52 hours. The LEA burden will not increase. The 

total new estimated burden will be 11,785.32.

Burden Estimate SY 2011-2012 Collection

CSPR Part I and II SEA Burden 

hours

LEA Burden hours Total

Approximate # of agencies 53 14,600 14,653

Average burden per agency

30.84 hours .688 hours

Total for 1810-0614

1,643 hours 10,044.8 hours 11,687

The average hourly rate for staff in each of the SEAs and LEAs to prepare the responses to 

this information full collection, including proposed amendments is estimated to be $24.00.

Therefore, the total cost of the collection is estimated as $280,488, which is equivalent to 

11,687 X $24.00.

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 
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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

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.

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: 0

Total Annual Costs (O&M): 0

Total Annualized Costs Requested: 0

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, beyond the efforts normally associated with 

Department staff conducting program monitoring, would be to review the submitted data 

that each State submits to complete their CSPR.

The Department estimates the following: ten people, GS-13, two hours, X 53 SEAs = 

1,060 hours X 42.66 per hour=$45,220.

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).

This is a request for clearance for renewal of a currently approved collection. The 

collection has not changed from the previously approved collection, so the burden will 

stay the same.

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

tabulation and publication. Address any complex analytical techniques that will be 
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EDICS Tracking and OMB Number: (XXXX) 1810-0614

Revised: XX/XX/XXXX

RIN Number: N/A

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.

SEAs will be asked to submit Part I of the SY 2014-2015 CSPR to the Department in 

December 2015. Part II of the CSPR will be due in February 2016. After State 

submissions have been received, ED program staff will conduct a data quality review. 

During the review, SEAs will have the opportunity to correct and resubmit final data. 

Data quality review for Part I will be completed by April 2016. Part II data quality

review will be completed in May 2016. After final data have been certified by SEAs, ED 

will ensure that appropriate privacy protections have been applied to the data. Once the 

documents are ready, ED will publish each SEA’s CSPR on our website at www.ed.gov. 

Reports will be posted in Summer 2016.

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.

Approval to not display expiration date has not been requested.

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

of Paperwork Reduction Act.

No exceptions were identified.

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SEC.9303. Consolidated Reporting – (a) In general: In order to simplify reporting requirements 

and reduce reporting burdens, the Secretary shall establish procedures and criteria under which a 

State educational agency, in consultation with the Governor of the State, may submit a 

consolidated State annual report. (b) Contents: The report shall contain information about the 

programs included in the report, including the performance of the State under those programs, 

and other matters as the Secretary determines are necessary, such as monitoring activities. (c) 

Replacement: The report shall replace separate individual annual reports for the programs 

included in the consolidated State annual report.