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Paperwork Reduction Act Submission Supporting Statement

Rural Education Achievement Program (REAP)

Information Collection to Support Grant Funding Process 

Introduction 

This data collection is pursuant to the Secretary’s authority under Part B of Title VI of the 

Elementary and Secondary Education Act (ESEA), to award funds under two grant 

programs designed to address the unique needs of rural school districts – the Small, Rural 

School Achievement (SRSA) program (ESEA Section 6212) and the Rural and LowIncome School (RLIS) program (ESEA Section 6221). 

Under the SRSA program, the Secretary awards grants directly to eligible local educational 

agencies (LEAs) on a formula basis. Under the RLIS program, eligible school districts are 

sub-recipients of funds the Department awards to State educational agencies (SEAs) on a 

formula basis. For both grant programs, the Department awards funds based on a 

determination of the eligibility of individual school districts and the calculation of the 

allocation each eligible district should receive according to formula prescribed in the 

statute. 

This data collection package consists of two forms and related documents that are used to 

accomplish the grant award process each year: (1) a spreadsheet used by SEAs to submit 

information to identify RLIS and SRSA-eligible LEAs and to allocate funds based on the 

appropriate formula, and (2) an application form for SRSA-eligible LEAs to apply for 

funding.

This submission requests a three-year extension of the current approved collection package 

(OMB #1810-0646). The REAP eligibility spreadsheet (Form 1) includes the following editorial 

upgrades:

a) a column has been added on the spreadsheet that lists the changes in school 

status from the previous year (i.e. newly-opened, closed, merged) that have 

been received by the Department via EDFacts. In prior years, SEAs were asked 

to list any closed, newly- opened, or merged LEAs on the Corrections 

Spreadsheet; now, States merely have to indicate their concurrence or their 

disagreement with the EDFacts data already provided;

b) the REAP eligibility spreadsheet also includes a column that gives a preliminary 

indication as to whether a district will be eligible for SRSA or RLIS. This column 

is auto-formatted to display this indication, using the eligibility information 

provided in other columns on the spreadsheet. Previously, there was no means 

to determine at a glance how the data entered by SEAs impacted an LEA’s 
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eligibility for SRSA for RLIS funding; 

c) Pursuant to the REAP Burden Reduction Initiative, the eligibility spreadsheet no 

longer asks SEAs to provide AYP status or REAP-Flex participation data. In prior 

years, the Department requested that SEAs provide this data along with the 

REAP eligibility data each year. Now, the Department receives annual REAPFlex participation and AYP status via EDFacts, thereby eliminating the need for 

SEAs to provide this data on the REAP spreadsheets.

These upgrades are incorporated to simplify and improve the clarity of the eligibility 

spreadsheets; none of these edits require SEAs to submit additional data. 

The SRSA Application (Form 2) is essentially unchanged from the previous collection.

The instructions accompanying both Form 1 and Form 2 have been edited to improve 

clarity and data quality, and other minor changes have been made to update dates and 

contact information. None of the upgrades described here require SEAs to submit 

additional data.

A. Justification

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. 

Part B of Title VI of the Elementary and Secondary Education Act (ESEA), as amended 

by the No Child Left Behind Act (P.L. 107-110), authorizes the Secretary of Education 

to award funds under two grant programs that are designed to address the unique 

needs of rural school districts – the Small, Rural School Achievement Program (ESEA 

Section 6212) and the Rural and Low-Income School Program (ESEA Section 6221). 

The Department awards funds for both grant programs based on a determination of the 

eligibility of individual school districts, and calculating formula allocations for each eligible 

district. An extension of this data collection package is needed to provide the information 

necessary for the Department to make the grant awards.

Form 1 consists of a spreadsheet through which SEAs provide to the Department 

eligibility and allocation data for both the RLIS and SRSA programs. Additionally, Form 1 

is supplemented with:

(a) a document that SEAs use to submit corrections to the REAP spreadsheet;

(b) a form for SEAs to report the LEAs in their States that meet the statutory 

alternative rural definition; and

(c) a form through which SEAs can obtain or verify the NCES local code 

assignment of individual schools within a district.

Form 2 consists of the application package for LEAs under the REAP Small, Rural School 

Achievement (SRSA) program (CFDA #84.358A). 
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Under the SRSA program, the Secretary awards grants directly to LEAs on a formula 

basis. Eligibility for this program is based on rural status and average daily attendance 

(ADA) for the district by December 1

st of each year. To be eligible, an LEA must: 1) (a) 

have a total ADA of less than 600 students, or (b) serve only schools located in counties 

with a total population density of fewer than 10 persons per square mile; and 2) (a) serve 

only schools that have an NCES school locale code of 7 or 8, or (b) be located in an area 

of the State defined as rural by a governmental agency of that State. Allocations are 

based on the ADA numbers for eligible LEAs and the LEA’s previous year’s allocations 

under the following ESEA provisions: 1) subpart 2 of Title II (Teacher and Principal 

Training and Recruiting); 2) section 2412(a)(2)(A) of Title II (Technology Grants); 3) section 

4114 (Safe and Drug Free Schools); and 4) Part A of Title V (Innovative Programs). 

The Department collects only information that is essential to making the awards in the 

SRSA application form. As a result, the SRSA application form is only one page. In 

addition, the Department requires eligible LEAs to apply only once, during their initial 

funding year; the applications are retained and used for each succeeding fiscal year for 

which the LEA remains eligible for a grant under the SRSA program. 

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 information collected from SEAs through Form 1, the REAP eligibility spreadsheet, 

which collects eligibility and allocation data, is used by the program office in coordination 

with Budget Service to determine school district eligibility for the program and to allocate 

funds to eligible districts.

The information from Form 2 (the SRSA application package) is used to process grant 

awards under the SRSA program.

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.

SEAs submit the REAP eligibility spreadsheets via email, while SRSA- eligible LEAs submit

their applications through the Department’s G5 electronic submission system. 

Additionally, with regard to the REAP eligibility spreadsheets (Form 1), The REAP Program 

Office is proposing to use the MAX data and collaboration portal 

(https://max.omb.gov/maxportal/) to collect REAP eligibility data, track changes to that

data, and interface with SEAs online. This OMB-sponsored portal provides authentication 

services, collaboration systems, data collection and tracking mechanisms, document 

publishing, and more.
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Currently, the data for the REAP eligibility spreadsheets and supporting documents is 

collected and revised via email communication with SEAs. The Program Office is 

proposing to use the MAX data and collaboration portal to replace the e-mail based data 

submission procedures now used by the REAP Program Office and its SEA respondents. 

This OMB-sponsored portal will help SEAs by providing a more direct, efficient, and 

accurate system of data collection and communication with the Program Office.

4. 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.

Form 1 (the REAP Eligibility Spreadsheet under OMB 1810-0646) collects from States LEA 

level data that is required to determine LEA eligibility to participate in both REAP formula 

grant programs program and to determine LEA level budget allocations. The system that 

we have instituted for determining eligibility is time-bound and incorporates data from 

several sources. The process that we use is similar to the processes the Department uses 

to determine eligibility and allocations for Title I and other formula grant programs, none of 

which relies solely on EDFacts as the data source for making those determinations. After 

numerous discussions with EDFacts staff, we have determined jointly that it is not feasible 

at this juncture for EDFacts data to be the primary source of data support the REAP 

eligibility determination process. As an example of the REAP Program’s need to rely on 

data outside of EDFacts, the LEA-level average daily attendance (ADA) that we collect 

from SEAs on the REAP eligibility spreadsheets is defined in Section 6231 of the REAP 

statute as:

“a census to determine the number of students in average daily attendance

in kindergarten through grade 12 at the schools served by the agency”

This definition is not consistent with the definition of ADA that States use to provide ADA 

for the EDFacts collection.

Nonetheless, we have explored with EDFacts ways that EDFacts data might support our 

needs. For the past three years, the REAP program office has collaborated with EDFacts

staff to align, to the extent possible, REAP data definitions and elements with EDFacts

data collection protocols. Our objective here is to shift a number of data elements from the 

REAP spreadsheet to the EDFacts annual data collection, and thereby reduce the annual 

reporting burden that REAP imposes on States. The success of this collaboration is 

evidenced by the fact that beginning in SY 2011-12, the program office will collect the 

REAP AYP and REAP-Flex participation data through EDFacts; we will no longer need to 

request these data from SEAs as part of this collection. 

In addition, we do use data from the EDFacts/CCD collection to provide our universe of 

schools. NCES Locale code data comes from the Census. We then match the locale

code data to individual schools within each district to determine each district’s eligibility 

based on locale codes. The poverty data we use for RLIS eligibility also comes from 

Census. 
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Form 2 (the SRSA Application Package) requests a subset of the information requested in 

Standard Form 424 (Application for Federal Financial Assistance), which consists of the 

minimum needed to make grant awards. The only information that is common to Form 424 

and the Form 1 (Eligibility Spreadsheet) of this collection is the NCES LEA ID number, 

which will be used to link allocation and application data to make awards. We would not be 

able to make this link without the ID number. 

However, at this point in time, the data that SRSA requires and the timelines within which 

those data are needed to make eligibility determinations and allocation decisions are not 

identical to the EDFacts data element definitions and timelines for data collection. The 

program office will continue to re-visit these issues and explore ways to reduce the burden 

to SEAs. 

5. Information impacts small businesses or other small entities (Item 8b of IC Data Part 

2), describe any methods used to minimize burden.

Neither small businesses nor small entities are affected by this collection.

6. 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.

Small LEAs are affected by this program. In order to minimize burden for these small 

entities, the Department proposes an application package that contains minimal request for 

data- a subset of the information requested in Standard Form 424 and information required 

by the statute. The Department also intends to make these applications available as 

electronic applications, which will also minimize burden.

If the information requested is not collected, the Department will be unable to make grant 

awards, because the formula allocations cannot be calculated without data from SEAs and 

LEAs. 

7. Special circumstances that would cause an information collection to be conducted 

in a manner inconsistent with 5 CFR 1320. 5.

This collection is consistent with the paperwork burden regulations of 5 CFR 1320.5.

8. 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.

The Department consulted with 9 SEAs and asked them to estimate the burden for these 

collections at the district level. The burden estimates in this document are based on those 

responses. The Department has not received comments from SEAs or LEAs on the issue 
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of data collection and burden during the past two years that the collection package has 

been in use.

9. Payment or gifts to respondents, other than remuneration of contractors or grantees.

No payment or gifts will be provided.

10. Assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulations, or agency policy.

There is no assurance of confidentiality. All data collected is in the public domain.

11.Justification for any questions of a sensitive nature, such as sexual behavior and 

attitudes, religious beliefs, and other matters that are commonly considered private.

This collection does not ask questions of a sensitive nature.

12.Estimates of the hour burden of the collection of information and the annualized 

cost to respondents of the hour burdens for collections of information, identifying 

and using appropriate wage rate categories.

The total annual reporting and recordkeeping burden for the collection is estimated to be 

3,377 hours. 

For Form 1 (the REAP Eligibility Spreadsheet, the subject of this clearance) the maximum 

number of respondents is 49 SEAs. The average burden per respondent is 40 hours and 

number of responses per applicant is one per annum. The total estimated burden to SEAs 

is estimated to be 1,960 hours per annum. In addition, LEAs will review and verify the data 

entered by the State at an estimated burden of 15 minutes per LEA for 5,000 LEAs. The 

total LEA burden is approximately 1,250 hours. The total estimated burden hours for Form 

1 for SEAs and LEAs combined is 3,210 hours.

For Form 2 (the Small, Rural School Achievement Program Application, the subject of this 

clearance), the maximum number of respondents is 500. The average burden per 

response is 20 minutes and total number of responses per applicant is one. The data 

collection occurs annually. Based on 500 responses, which will take an average of 20 

minutes per applicant to complete report, the total burden is approximately 167 hours.

Estimate of the total annual cost burden to respondents or record keepers for capital 

expenses resulting from the collection of information. 

The total annual cost burden to respondents is estimated at $59,230. 

For Form 1 (the REAP Eligibility Spreadsheet), primary costs to respondents fall into the 

following categories: collection of data, filling in information in the spreadsheet, review of 

data, and e-mailing the form. Based on an estimate of 49 forms prepared and submitted 
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annually, costs to respondents are estimated to be the following:

Collecting data

49 forms X 36 hours /form X $25/hour = $ 44,100

Filling in information 

49 forms X 1.5 hours /form X $10/hour = $735

Data Collection/Review 

5,000 LEAs X .25 hours/review X $10/hour = $12,500

E- mailing report 

49 forms X .5 hours /form X $10/hour = $ 245

Total cost to respondents $57,580

For Form 2 (the Small, Rural School Achievement Program Application), the primary cost 

to respondents is for filling out the electronic application form. Based on an estimate of 

500 applications prepared and submitted annually, costs to respondents are estimated to 

be the following:

500 applications X .33 hours /application X $10/hour = $1,650

13.Estimate of the total annual cost burden to respondents or record keepers for capital 

expenses resulting from the collection of information. 

This information collection does not require the use of any capital equipment, start-up costs 

or record keeping not included in the response to question # 12.

14.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. 

For Form 1 (the REAP Eligibility Spreadsheet), program costs entail reviewing completed 

spreadsheets for completeness; downloading data submitted electronically; calculating 

allocations; and notifying States of allocations for the State and districts.

Downloading data submitted electronically

.5 hours/form X 49 forms X $40/hour = $980 

Reviewing completed spreadsheets for completeness:

1.5 hours/form X 49 forms X $40/hour = $2,940 

Calculating allocations

.5 hours/form X 49 forms X $40/hour = $ 980

Notifying States of allocations for the State and districts.

.5 hours/form X 49 forms X $40/hour = $ 980 

.5 hours/form X 49 forms X $12/hour = $ 294 
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TOTAL $ 6,174 

For Form 2 (the Small, Rural School Achievement Program Application), program costs 

entail screening applications for eligibility; downloading allocation data into GAPS; making 

grant awards; and mailing award notifications.

screening applications for eligibility 20 hours X $40/hour = $ 800

downloading allocation data into GAPS 8 hours X $40/hour = $ 320

making grant awards 250 hours X $40/hour = $10,000

mailing award notifications 150 hours X $12/hour = $ 1,800

TOTAL $12,920

15. Reasons for any program changes or adjustments.

With regard to Form 1 (the REAP Eligibility Spreadsheet), we have reduced the maximum 

number of SEA respondents from 52 to 49; the District of Columbia, Hawaii, and Puerto Rico 

are unitary districts, and by virtue of their demographics do not meet the eligibility criteria for 

either RLIS or SRSA. In addition, this collection will no longer ask SEAs to provide REAP-Flex 

or AYP data.

With regard to Form 2 (the the Small, Rural School Achievement Program Application), the 

Office of General Counsel has determined that SRSA LEAs need not apply every year, so the 

Department has reduced the previous estimate of 4,500 applicants to an estimated 500 

applicants.

16. Plans for tabulation and publication. 

The Department will publish the list of grantees under each program and their allocations. 

Allocations are based on the formulas required by the statute. No complex analytical 

techniques will be used. 

17. Reasons not display the expiration date for OMB approval. 

The information collection will display the expiration date for OMB approval.

18. Exception to the certification statement identified in the “Certification for 

Paperwork Reduction Act Submissions.”

 There are no exceptions to the certification statement.

19. Collections of Information Employing Statistical Methods

 This information collection will not employ statistical methods.