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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 copy of the appropriate section of each statute and regulation mandating or 

authorizing the collection of information.

The ED 524 form and instructions are included in U.S. Department of Education (ED) 

discretionary grant application packages and are needed in order for applicants to submit 

summary-level budget data by budget category, as well as a detailed budget narrative, to 

request and justify their proposed grant budgets as part of their grant applications. At the 

time of application, ED applicants submit budget information on the ED 524 for both Federal 

funds requested and for the non-Federal match or cost-sharing funds they are committing to 

the proposed project (either statutorily required or provided as a voluntary commitment) for 

each budget period of a multi-year project. Please note that Education Department General 

Administrative Regulations(EDGAR),(34 CFR 75.117) requires that an applicant that proposes a 

multi-year project must include in its application a budget narrative accompanied by a budget 

form prescribed by the Secretary, that provides budget information for each budget period of 

the proposed project period. In order to prepare the non-Federal portion of the budget for the 

ED 524, the applicant must already have had this information on hand in their internal grant 

accounting records. Under EDGAR, 34 CFR 74.23 and 80.24, as applicable, a grantee is required 

to maintain this information regarding cost-sharing and matching resources. 

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 ED 524 collection establishes uniform categories of cost and a standard format for 

requesting costs for all budget periods of a multi-year project. ED applicants that are applying 

for multi-year projects, submit a budget for all years of the grant’s proposed project period 

(typically 3 to 5 years), with their initial grant applications (EDGAR, 34 CFR 75.117). ED uses 

this information to evaluate the reasonableness, allowability, and allocability of funds that the 

applicant requests to support ED-sponsored grant projects (EDGAR, 34 CFR 75.232). The 

applicant is required to submit a separate ED 524 for each application it submits to the 

Department.
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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 of using information technology to reduce burden.

The Department continues to take part in the P.L.106-107 electronic government task forces 

and participates as a full partner in E-Gov/Grants.gov. The Department has increased its 

participation and the building and posting of grant application packages in the Grants.gov Web 

Portal. As of FY 2007, 100% of ED’s discretionary grant competitions were available in 

Grants.gov and all ED discretionary grant competitions that were able to, participated in 

Grants.gov APPLY. 

Please note that ED is an active participant in interagency efforts to streamline grant 

application forms and to create standard data elements that will be used by applicants and 

grantees in Grants.gov. In addition, over the last three years ED has made a concerted effort 

to move as many programs as possible that were previously using a program-specific budget 

form opposed to using the ED 524. 

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use of the purposes described in Item 

2 above.

Consistent with EDGAR requirements found in 34 CFR 75.117, the applicant submits the Budget 

Information Non-Construction form, ED 524, along with the grant proposal to describe the 

proposed budget layout to run a particular project. This information is unique to each project, 

which is specifically designed for a particular program competition, and thus is not available 

anywhere else.

5. If the collection of information impacts small businesses or other small entities (Item 

8b of IC Data Part 2), describe any methods used to minimize burden.

Under EDGAR regulations, all requirements for small entities are minimized

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.

Failure to collect the budget information on the Budget Information Non-Construction 

Programs form, ED 524, from each applicant would make it nearly impossible for the 

Department to make a fair and accurate assessment of the reasonableness, allowability, and 
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allocability of the applicant’s request for Federal funds and to provide a level of funding that 

could be justified. 

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 which 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 information will not be collected in a manner inconsistent with the general 

information collection guidelines.

8. If applicable, provide a copy and identify the date and page number of publication in 

the Federal Register of the agency’s notice, 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.

The Department published a 60 day notice on February 13, 2014 (79 FR 8687). No public 

comments were received. A 30-day Federal Register Notice was published.

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

remuneration of contractors or grantees.

There are no payments or gifts to respondents other than the allocation of federal funds that 

result from the information collection.

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

the assurance in statute, regulation, or agency policy.

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.

This information collection does not include information of a sensitive nature.

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

statement should :

 Indicate the number of respondents, frequency of response, annual hour 

burden, and an explanation of how the burden was estimated. 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.
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 If this request for approval covers more than one form, provide separate hour 

burden estimates for each form and aggregate the hour burdens in item 16 of 

IC Data Part 1.

 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 not be included in Item 14.

Total Annual Burden Hour Calculation for Budget Information Form, ED 524: Total annual 

burden hours for ED 524: 94,500

Approximately 5,400 respondents submitted grant applications in FY 2013. The total annual 

hour burden estimate is 94,500. The burden hour per response is estimated to average 17.5 

hours. 

17.5 hours/response (average) X 5,400 responses/year = 94,500 total annual burden hours 

Estimated Total Annualized Cost to Respondents for completing and submitting the ED 524: 

$2,362,500

17.5 hours/response (average) X 5,400/year X $25/hour = $2,362,500

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 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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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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested : $ .00

No start-up costs.

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.

Total Annual Cost to the Federal Government for Budget Information form, ED FORM 524: 

$445,608

The total annual cost is based on the following:

2 hours per response x 5,400 responses x $41.26/per hour (average DC-area GS-12 hourly rate) 

= $445,608

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

Due to a reduction in funding and sequestration to the Department’s discretionary grant 

programs there was a decrease in the number of discretionary grant applications received and

an adjustment of a decrease in burden hours of 236,250. 

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.
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No plans exist to publish the results of this information 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 approval to not display the expiration date for this information collection.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.