1 **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION** 

OMB Number: 1855 - 0015 

### A. Justification 1. Explain the circumstances that make the collection of information necessary. I dentify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or auth orizing 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 ty pe of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This is a request for a 3

- year clearance to collect information about scholarship applicants for the DC School Choice Incentive Program (Program) , and preliminary information for the evalu ation. The Program was reauthorized on April 15, 2011 through "District of Columbia, Federal Funds, Federal Payment for School Improvement" . Speaker Boehner introduced the Scholarships for Opportunity and Results (SOAR) Act which reauthorized the DC School Choice Incentive Program for another five years beginning in FY 2011. The DC School Choice Incentive Program, authorized by the Consolidated Appropriations Act of 2004, awarded a grant to the D.C. Children and Youth Investment Trust Corporation that will administer scholarships to students who reside in the District of Columbia and come from households whose incomes do not exceed 185% of the poverty line. Pr iority is given to students who are currently attending schools in need of improvement, as defined by Title I. To assist in the student selection and assignment process, the information to be collected will be used to determine the eligibility of those students who are interested in the available scholarships. Also, since the authorizing statute requires an evaluation we are proposing to collect certain family demographic information because they are important predictors of school success. Finally, we ar e asking to collect information about parental participation and satisfaction because these are key topics that the statute requires the evaluation to address. 2. Indicate how, b y 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 collection will be used to collect basic information about applicants for DC School Choice Incentive scholarships and preliminary informati on for the evaluation. Failure to collect this information will hinder the grantee’s ability to select students for the scholarships, administer the student lottery, identify the number of slots available in participating schools, to effectively manage the distribution of scholarships to low

- income parents of students, and to meet certain evaluation and reporting requirements, as required by the statute. In turn, this will negatively impact the entire program by risking fair and2

equitable access to the exp anded educational options for low

- income parents in the District of Columbia. 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. Since responses will be s ubmitted in hard copy, the collection of information does not involve the use of automated, electronic, or mechanical forms of information technology. 4. Describe ef

forts to identify

duplication. Show specificall y wh y an y similar information already available cannot be used or modified for use for the purposes described in Question 2 above. We have made the determination that a duplication of effort does not exist, since the respondents are unique to this narrowly tailored grant program. To the best of our knowledge, there is no other information collection that is available to fulfill this request. 5. If the collection of information impacts small businesses or other small entities, describe any m ethods 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 independentl y 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. There i s no anticipated impact on small business or other small entities (as stated in Item 5 of OMB For 83

- 1). 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as any t echnical or legal obstacles to reducing burden. The statute requires that the grantee conduct an extensive public education campaign, in which parents’ apply for scholarships, and that the grantee identifies participating schools, administers a student lottery, and, conducts the student selection and assignment process. Additionally, the grantee will participate in evaluating programmatic activities. The negative consequences of not performing the information collection requested could be detrimental to the notification to parents about the expanded options, filling the available slots in participating schools, distribution of student scholarships, and overall nullify the management, evaluation and administration of the grant program.3

7. Explain any

speci al circumstances that would cause an information collection to be conducted in a manner:  requiring respondents to report information to the agency more often than quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 mor e than three ye ars;  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 b y 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 in formation ’ s confidentiality to the extent permitted by law. There are no special circumstances. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the inf ormation 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. Specificall y 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 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 and 30

- day Federal Register Notice (FRN), and received no public comments during the 60

- day FRN period .4

9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification . There is no payment or gift to respondents, other than remuneration of contractors or grantees (upon the completion of the grant competition and award of the contract for the evaluation of the program). 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency polic y. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC RAS’ Part 2 I C 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 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 Personall y Identifiable Information, OM:6 - 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally I dentifiable Information) . If the collection is subject to the Privacy Act, the P rivacy

Act statement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. Based upon the assurance in statute, regulation , or agency policy for discretionary grant programs, the Department’s disclosure polices adheres to the provisions under the Privacy Act. A SORN was published in vol. 69 no. 79 page 22014 on 4/23/2004. 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. 12. Provide estimates of the hour burden of the collection of information. The statement should:  Indicate the number of respondents by affected public ty

pe (federal g overnment, 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 burden5 was estimated, including identification of burden ty pe: recordkeeping, reporting or third party

disclosure. All narrative should be included in Question 12. Unless directed to do so, agencies should not conduct special survey s 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 i s expected to vary widel y 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 pra ctices.  If this request for approval covers more than one form, provide separate hour burden estimates for each form . (The table should at minimum include Respondent ty pes, Number of Respondent s and Responses, Hours/Response, and Total Hours)  Provide esti mates 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 i ncluded here. Instead, this cost should be included in Question 14.

 **Collection Number of**  **Respondents Frequency**  **Number of Responses**  **Average**

**Hours Total**  **Information 3,000**  **1 3,000**  **.33(20 min)**  **990** The annual number of responses for this collection is 3,000, with 3,000 respondents taking 20 minutes to complete, for a total of 990 annual burden hours. The Department is maintaining the current OMB inventory of 1,000 hours. 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 Question s 12 and 14.)  The cost estimate should be split into two compon ents: (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 s ys tem 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 rec ord storage facilities.  If cost estimates are expected to vary widel y, 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 burde n estimate. In6 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 anal ys is 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 Question 12 . Total Annualized Capital/Startup Cost: Total Annual Costs (O&M): Total Annualized Costs Requested: The costs are minimal, because the program will be administered by the grantee. 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 an y other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Questions 12, 13, and 14 in a single table. **Work Estimate Number of** 

**Employees Pay Rate**  **Cost per Hour Average**  **# of Hours**  **Total Analysis and**  **processing 1**  **GS -**  **13 $41.00**  **10 $410.00**  Costs to the Federal Government have been assessed at one employee at a GS13 hourly rate of $41.00 taking an average of 10 hours to complete, for a total of $410.00. 15. Explain the reasons for any program changes or adjustments. Generall y, 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 s ize of the reporting universe). Program changes result from a deliberate action that materiall y changes a collection of information and generall y 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 b y ty pe of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty pe of collection (new, revision, extension, reinstatement with change , reinstatement7

without change) and include totals for changes in burden hours , responses and cost s (if applicable) . There are no program changes or adjustments to this ICR . 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex anal yt ical techniques that will be used. The results of the information collection will not be published. 17. Provide the time schedule for the entire project, including beginning and ending dates of the colle ction of information, completion of report, publication dates, and other actions. 18. 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. 19. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. 20. We are not requesting any exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83

- 1.