SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

OMB No.1810-0686

MIGRANT EDUCATION PROGRAM (MEP)

MIGRANT STUDENT INFORMATION EXCHANGE

A. Justification 

Q1. 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 

A1. While, the U.S. Department of Education (ED) is proposing new regulations to implement the 

Migrant Student Information Exchange (MSIX), a nationwide, electronic records exchange mechanism 

mandated under Title I, Part C of the Elementary and Secondary Education Act (ESEA), as amended by 

the No Child left Behind Act; pursuant to the Paperwork Reduction Act, ED is extending the nonregulatory data collection for extension and approval. As a condition of receiving a grant of funds under 

the Migrant Education Program (MEP), each State educational agency (SEA) would be required to 

collect, maintain, and submit minimum health and education-related data to MSIX within established 

timeframes. The proposed regulations would facilitate timely school enrollment, placement, and accrual 

of secondary course credits for migratory children and help us determine accurate migratory child counts 

and meet other MEP reporting requirements. The MEP is authorized under sections 1301-1309 in Title I, 

Part C of the ESEA. MSIX and the minimum data elements (MDEs) are authorized specifically under 

section 1308(b) of the ESEA. 

ED is requesting approval to extend the 1810-0686 information collection that supports statutory 

requirements for data collection under Title I, Part C MEP. The purpose of the MSIX user application is 

to collect data to verify the identity of users in order to grant them access to the MSIX system for the 

purpose of transferring migrant student data. The application collects information on an MSIX user’s 

identity, title/position, work address, work telephone, email, and role. 

Q2. 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 

A2. The information that would be collected and maintained in MSIX consists of information about 

individual users in the State that are granted access to MSIX in order to enter, review, and download 

migrant student data. The information will be used to verify a potential MSIX user’s identity and the 

appropriate level of access to MSIX information. The State does not have to use the application form 

provided to them by the Department of Education - it is simply a suggested application to verify a user’s 

identity and role. However, each State that provides access to MSIX is required under its separate MSIX 

Interconnection Agreement (IA) with the Department to ensure that only authorized individuals have 

access to the MSIX system. The MSIX user application can be used to help fulfill this requirement and 

document that the State met its obligation as stated in its MSIX IA. 

Q3. 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. 

A3. The State User Administrator can download the form provided in the MSIX User Access Guide and 

Application from the MSIX system at https://msix.ed.gov/msix/contactUs.html or create their own 

System User Access form. If the States use their own system access form, the fields must be the same as 

those contained in the MSIX User Access Guide. 

Q4. 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. 

A4. The MSIX information collection will not duplicate (or otherwise include) the burden of other 

information collections. The users of MSIX are a uniquely State-identified set of users for each State. 

There is currently no collection of the names and work addresses for individuals that have been identified 

as needing access to MSIX for the purposes of enrollment, placement and accrual of credits for the 

migrant children in each state. In addition, no other authorized Department collection contains the names 

of these individuals. 

Q5. If the collection of information impacts small businesses or other small entities. 

A5. Small business and/or small entities are not impacted by this data collection. 

Q6. 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. 

A6 . Consequences are as follows: 

(1) There would be no record of authorized participants in the MSIX; 

(2) There is no way to be assured that only approved personnel in the States are participating in MSIX; 

(3) There would be no way to assure all authorized personnel have been granted the correct level of 

access. 

Q7. Explain any special circumstance 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 that 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. 

A7. There are no special circumstances. 
Q8. 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 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. 

A8. ED published both a 60-and 30-day FRN seeking comments, there were no comments received during 

the 60-day comment period. 

Also, under rulemaking requirements ED published a proposed rule notice in the Federal Register on 

12/27/2013 under 78 FR 79222 requesting comments. Comments will be summarized and used to finalize 

the data collection with the Final Regulations. The user application form was developed by the MSIX 

Team in collaboration with eight States. 

Q9. Explain any decisions to provide any payment or gifts to respondents, other than remuneration of 

contractors or grantees. 

A9. No gifts or payments will be provided to respondents. 

Q10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance 

in statute, regulations, or agency policy. 

A10. That part of the users’ access form defined as “directory information” is public information. 

Directory information is defined as a user’s name, work address, work telephone, email address, and 

access level, which is used only to grant that person access to MSIX. All persons who access MSIX must 

accept and sign the MSIX Rules of Behavior, which is a detailed description of the safeguards that each 

system user must comply with in order to protect the privacy and security of the information. 

The privacy notice included on the application states that without the respondent’s consent, the 

Department may disclose information provided to entities under a published "routine use." Under such a 

routine use, we may disclose information: 

1) To a third party contractor that we have hired to perform any function that requires disclosure of 

records in this system to employees of the contractor; 

2) To a researcher if an appropriate official of the Department determines that the researcher or relevant 

organization is qualified to carry out specific research related to the MSIX system; 

3) To the U.S. Department of Justice (DOJ) or the Office of Management and Budget (OMB) if the 

Department concludes that disclosure is desirable or necessary to determine whether particular records are 

required to be disclosed under Freedom of Information Act or the Privacy Act; or 

4) To appropriate agencies, entities, and persons when: a. It is suspected or confirmed that the security or 

confidentiality of information in MSIX User Application Form has been compromised; 

b. The Department has determined that as a result of the suspected or confirmed compromise, there is a 

risk of harm to economic or property interests, identity theft or fraud, or harm to the security or integrity 

of MSIX User Application Form or other systems or programs (whether maintained by the Department or 

by another agency or entity) that rely upon the compromised information; and, 
c. The disclosure is made to such agencies, entities, and persons who are reasonably necessary to assist 

the Department in responding to the suspected or confirmed compromise and in helping the Department 

prevent, minimize, or remedy such harm. 

Q11. 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. This 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. 

A11. There are no questions of a sensitive nature. 

Q12. Provide estimates of the hour burden of the collection of information 

A12. The 47 SEA/LEA User Administrators will be responsible for recording data collected on each form 

in the MSIX system. It is estimated that it will take 10 minutes per application to establish an account. 

An estimated 52 users will apply for entry into the MSIX system on an annual basis resulting in an 

estimated 10,452 responses. We estimate that it will take 30 minutes to complete each user application 

form. This includes providing the user’s work-related and personal information as well as acquiring 

signatures from the approving officials. 

Total Burden Hours 

Respondent 

Type 

Obligation to 

Respond 

Hours/Response No. of 

Responses 

Total Burden 

MSIX Users Required 30 minutes 10,452 3,476 hours 

The initial cost of burden for an estimated at 30 minutes per entry at $31.34 an hour, equals a projected 

annual cost of $25,040.66 

Q13 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). 

A13. There are no costs to respondents. 

Q14. Provide estimated annualized cost to the Federal government. 

A14. There are no annualized costs to the Federal government. The collection and review effort is perform 

by 47 SEA participating in the Migrant Education Program (MEP). 

Q15. Explain the reasons for any program changes or adjustments reported. 

A15. This is an extension of an approved information collection request; there are no program changes or 

adjustments to burden or respondents. Cost adjustments are based on the GSA median price ($31.34) for 

an entry level Administration/clerical (101G-1). Once the regulation becomes final if there are program 

changes, the changes will be reported to OMB for change. 
Q16. 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 or 

report, publication dates, and other actions. 

A16. The collection of information does not require publication of the information or use of complex 

analytical techniques. Summary information may be reported by the Secretary in tabular form to the 

States, Congress and the public. 

Q17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate. 

A17. ED is not seeking this approval. 

Q18. Explain each exception to the certification statement identified in the “Certification for Paperwork 

Reduction Act Submissions. “ 

A18. There are no proposed exemptions to the certifications. 

B. Collections of Information Employing Statistical Methods 

The data collection does not require that statistical methodology be employed.