1

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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 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 section1. 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.

This application is being submitted for reinstatement without changes because there will be a 

grant competition in FY 2015. The program is authorized under Title III, Part A, Section 320 

(84.031L) of the Higher Education Act (HEA) of 1965, as amended

(http://legcounsel.house.gov/Comps/Higher%20Education%20Act%20Of%201965.pdf). This 

program awards discretionary grants to eligible institutions of higher education so that they

might increase their self-sufficiency by improving academic programs, institutional 

management, and fiscal stability.

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 collection of information is gathered electronically by the Department for the purpose of 

obtaining programmatic and budgetary information needed to evaluate applications and to make 

funding decision based on the authorizing statute and the 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.

The application process is electronic. Applicants will submit their applications using the 

government-wide Grants.gov system. The applications will then transfer to the Department’s G5 

system. Program staff will use the G5 system to set up the panels for the competitive reading, 

and the peer reviewers will use G5 to read and score the applications. 

 

1

Please limit pasted text to no longer than 3 paragraphs.
2

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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.

Since the information submitted in this application is unique to each respondent and to the 

authorization legislation, no duplication exists.

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 not-for-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.

This collection of information does not involve small businesses or small entities. 

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 Department uses this information to make new multi-year grant awards. If this information 

is not collected or collected less frequently, the Department would not be able to evaluate 

applications and make funding decisions based on the provisions of the authorizing statute. Data 

is only collected when the program appropriation amount is enough to fund new awards.

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 
3

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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.

There are no special circumstances as outlined in #7 of the instructions.

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 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.

A 30 day notice for public comment will be published in the Federal Register as required. 

Program staff will respond to any questions or comments resulting from the publication of the 

information collection in the Federal Register as required by 5 CFR 1320.8(d).

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

of contractors or grantees with meaningful justification.

The Department will not provide 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.2If the collection is subject to 

 

2

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 Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
4

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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.

The Department’s disclosure policies adhere to the provisions of the Privacy Act.

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.

Questions of a sensitive nature are not included in this information collection.

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.

Total estimated burden hours for this collection of information are 5,625 annually. We estimate 

75 respondents at 75 hours per response. Applications will be submitted electronically. Labor 

costs for data processing and generation of application in required format are $100.00. Annual 

cost to applicant to file and maintain application materials are $100.00.
5

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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 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 : 

There are 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.
6

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

Estimated annual cost to the Federal Government:

Development and Approval Process

(1 staff x 40 hours x $40 per hour) $ 1,600

Printing

(75 applications x $3 per app) $ 225

Peer Review Planning and Coordination

(15 days x 4 staff x $280 per day) $ 16,800

Peer Review (Stipends and Training)

(25 peer reviewers x $1,000) $ 25,000

Analyses and Evaluation

(15 days x 2 staff x $ 100 per day) $ 3,000

Monitoring of Grants

(160 hours x 1 staff x $40 per hour) $ 6,400

World Wide Web Preparation for Posting

(4 hours x 1 staff x $40 per hour) $ 160

Total estimated cost to the Federal Government $ 53,185

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).

Burden is increasing due to the fact that this collection is a reinstatement of a previously 

discontinued collection.

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 to publish the results. The information collected will be used for internal 

purposes only.

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.

There is no request to omit the OMB expiration date. The department will display the expiration 

date for the OMB approval on the form, as required.
7

EDICS Tracking and OMB Number: (XXXX) 1840-0798 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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

Paperwork Reduction Act.

This collection of information does not employ statistical methods.