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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB Number: 1855-0015

Revised 07/01/2014

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 section. Please limit pasted text to no longer than 3 pages. 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 is a request for a 3-year clearance to collect basic, time critical information about 

scholarship applicants for the DC School Choice Incentive Program (Program), and 

preliminary information for the evaluation. 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. Priority 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 are 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, 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 collection will be used to collect basic information about applicants for DC School 

Choice Incentive scholarships and preliminary information 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 
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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 and 

equitable access to the expanded 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 submitted in hard copy, the collection of information does not 

involve the use of automated, electronic, or mechanical forms of information technology.

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 

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 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.

There is 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 frequently, as well as any technical 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. 
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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 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. 

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.

The Department published a 60-day and 30-day FRN. 
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9. Explain any decision to provide any payment 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 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 ICRAS’ Part 2 IC 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 Personally Identifiable Information, OM:6-104 – Privacy

Act of 1974 (Collection, Use and Protection of Personally Identifiable Information). If 

the collection is subject to 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.

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 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 
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was estimated, including identification of burden type: recordkeeping, reporting or 

third party disclosure. All narrative should be included in Question 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. (The table should at minimum include Respondent types, 

Number of Respondents 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 

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 Questions 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 
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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 

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 any 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. 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 
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without change) and include totals for changes in burden hours, responses and costs (if 

applicable).

There are no program changes or adjustments.

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. 

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 collection 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.