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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Indian Education Formula Annual Performance Report

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 copy 

of the appropriate section of each statute and regulation mandating or authorizing the 

collection of information.

The purpose of Indian Education Formula Grant to Local Agencies, as authorized under Title 

VII, Part A, Subpart 1 of the Elementary and Secondary Education Act, as amended (ESEA) 

§§ 7111-7119, 20 U.S.C. §§7421-7429) is to assist applicants to provide Indian students with 

the opportunity to meet the same challenging state standards as all other students and meet 

the unique educational and culturally related academic needs of American Indian and Alaska 

Native students. The Indian Education Formula Grant (CFDA 84.060A) is not competitive 

or discretionary and requires the annual submission of the application from either a local

education agency (LEA) and/or tribe. The amount of the award for each applicant is 

determined by a formula based on the reported number of American Indian/Alaska Native 

students identified in the application, the state per pupil expenditure, and the total 

appropriation available. 

In the past, the Office of Indian Education (OIE) of the Department of Education (ED) 

collected annual performance data within the annual application. Due to restructuring of the 

application collection process, OIE has developed a separate annual performance report. The 

application and the annual performance report will both be housed in the Education Data 

Exchange Network (EDEN) Submission System. 

The 524B Annual Performance Report (APR) was designed for discretionary grants, however 

the title VII program is a formula grant program. Therefore, the EASIE APR goes beyond 

the generic 524B APR and facilitates the collection of more specific and comprehensive data

due to grantees entering project specific data into an online database. This will allow for a 

comparison of LEAs across objectives. By entering information into the EASIE APR

database, data will be able to be generated quickly and uniformly to facilitate data collection, 

as required under 34 CFR 75.720, and 2 CFR part 200.301. This APR will improve the 

quality of data collected that can be used for evaluation and to help make policy decisions,

reduce burden on the grantees, and allow ED to inform Congress on the outcomes of this 

grant program.

OMB Reporting History and Legislative Authority

The information collected is in compliance with 34 CFR 75.720, and 2 CFR part 200.301. 

Recipients must submit an APR demonstrating that substantial progress has been made 

towards meeting the approved objectives of the project. In addition, grantees are required to 
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report on their progress toward meeting the performance measures established for the ED 

grant 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. 

OIE program staff will collect information via the APR submitted by formula grantees in 

compliance with 34 CFR 75.720 and 2 CFR part 200.301. Grantees submit APRs once a 

year and OIE uses the APRs to monitor grantee progress toward performance objectives. 

OIE needs an APR that goes beyond the generic 524B APR to facilitate the collection of 

more standardized and comprehensive GPRA data. Grantees will enter GPRA data into a 

single format in an online database. This APR will improve the quality of data collected that 

can be used for evaluation and to help make policy decisions, reduce burden on the grantees, 

and allow ED to inform Congress on the outcomes of this grant 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 for adopting this means of collection. Also describe any 

consideration of information technology to reduce burden.

APR information will be collected electronically through a web-based system. The use of 

technology affords ED staff greater access to and use of data by (1) providing staff with

completed APRs more quickly; (2) aggregating and analyzing grantee responses to specific 

questions more quickly; and (3) storing and managing the 1,300 APRs received each year 

from grantees electronically. 

Electronic collection affords greater efficiency for grantees by (1) eliminating the need to 

print and mail the APR; (2) facilitating technical assistance from ED staff and a Partner 

Support Center who can view their responses online; (3) ensuring that all APR questions are 

completed fully and correctly. Grantees that do not have internet access are permitted to email, fax or mail the APR. 

The system also pre-populates information collected during EASIE Part II, so that ED does 

not request duplicate information from grantees. Student performance information collected 

by EDFacts, such as State assessment results, attendance statistics, and graduation rates, are 

pre-populated into EASIE so there is no additional burden to the applicant. The APR also 

calculates tables and charts to reduce burden on the grantees. 

4. 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.

There is no duplication of reporting on the APR. This information collection requests 
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information specifically for Indian Education Formula Grant to Local Agencies authorized 

under ESEA §§ 7111-7119. Although there are other Indian education programs in the 

Department, they are authorized under different legislation and their purposes and 

requirements differ from those under this program. 

5. If the collection of information impacts small businesses or other small entities (Item 5 

of OMB Form 83-1), describe any methods used to minimize burden.

This information collection requirement will impact small entities, but the Department will 

limit the collection to only that information necessary to make grant awards, in order to 

minimize the burden on 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.

Less frequent or no annual reporting risks waste, inefficiency and/or lack of progress on 

desired indicators due to insufficient oversight. Annual performance measurement is a 

requirement under 34 CFR 75.720 and 2 CFR Part 200.301. 

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner:

There are no special circumstances that require the collection to be conducted in a manner 

inconsistent with OMB guidelines as described.

 requiring respondents to report information to the agency more often than quarterly;

Respondents submit the information collection annually for each grant year.

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 The collection of information will not be less than 30 days. 

 requiring respondents to submit more than an original and two copies of any 

document;

Respondents are required to submit the APR electronically through a web-based system

unless they have no Internet connection or inadequate Web access. Grantees that meet the 

exception to submitting the APR electronically are not required 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;
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Respondents will not be required to retain 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 the study;

The information collection is not connected with a statistical survey.

 requiring the use of statistical data classification that has not been reviewed and 

approved by OMB;

The information collection is not connected with a statistical survey or statistical data 

classification.

 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

The information collection does not request data that is confidential. 

 requiring respondents to submit proprietary trade secrets, or other confidential 

information the agency can demonstrate that it has instituted procedures to protect the 

information's confidentiality to the extent permitted by law.

The information collection does not request data that is of a proprietary nature or 

confidential.

8. 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 any 

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 instructions and 

recordkeeping, 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.
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OIE will publish the appropriate Federal Register Notice to solicit public comment on this 

collection.

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

remuneration of contractors or grantees.

There are no payments or gifts to grantees in support of the data collection.

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

assurance in statute, regulation, or agency policy.

Confidential information is not requested. However, some applicants may include 

information within an application that is personally identifiable, such as contact information 

for staff. Any personally identifiable information is not released under the exemptions of the 

Freedom of Information Act (FOIA).

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. 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.

None of the questions in the APR concern topics commonly considered private or sensitive, 

such as religious beliefs or sexual practices.

12. Provide estimates of the hour burden of the collection of information. The statement 

should:

 Indicate the number of respondents, frequency of response, annual hour burden, and 

an explanation of how the burden was estimated. 

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate hour burden estimates for each form and 

aggregate the hour burdens in Item 13 of OMB Form 83-I.

 Provide estimates of annualized costs to respondents for 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 the cost should be included in Item 14.

In September 2015, grantees will be required to submit APR information in a web-based 

format. The average respondent burden for the APR is estimated to be 16 hours. The 

estimate includes reading instruction; collecting information; making appropriate 
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calculations; ensuring unduplicated counts of participants; answering all questions fully; 

completing the online forms and submitting these forms to ED. 

APR Information Collection

APR Sections 1-9 Time Comments

1. Project Director Name and Title and 

Authorized Representative Name and 

Title

20 minutes

2. Participation Data By Objective and 

Activity/Service

12 months x 60 minutes=12 hours Collecting participation data by 

activity or service of each 

objective. (1 hour a month X 12 

months)

2a. Comments 40 minutes

3. Program Objective Results 30 minutes The grantee will decide if the 

objective was met and will provide 

a description if objective was not 

met.

4a. Reading Assessments (All 

Students/Indian Students)

30 minutes (Optional) This section is prepopulated with EdFacts 

information. A grantee can select 

to modify the data.

4b. Mathematics Assessments (All 

Students/Indian Students)

30 minutes (Optional) This section is prepopulated with EdFacts 

information. A grantee can select 

to modify the data.

4c.. Summary of State Assessment Data 0 minutes Chart summarizes Assessment 

Information.

5. Attendance and Graduation Data 40 minutes

6. Budget Data 0 minutes This information will be 

prepopulated with budget 

information and budget 

information is calculated.

6a. Explanation if funds remain 

exceeding $1000.

40 minutes (Optional) The grantee will only 

need to write an explanation if 

$1,000 or more remain.

6b. Budget/Program specific 

questions/Certification

10 minutes Yes, No questions have been 

added to assist grantee in 

completing administrative tasks.

Total Burden 16 hours

Burden Hours
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Across all sites, the total hour burden is estimated as follows:

1,300 grantees x 16 hours per grantee = 20,800

The estimate can vary depending on the amount of information provided by each grantee. 

Respondent Costs

The program director of each grantee will complete the annual reporting forms and certify

the APR. These tasks will take an average of two hours. Administrative staff is expected to 

collect all other information and make necessary calculations. These tasks are estimated to 

take an average of 14 hours. 

The respondent cost estimates are computed using the hourly rates of a GS 5/1 for 

administrative assistant and GS 12/1 for a program director. These hourly rates are 

comparable to salaries of staff that will perform these functions for the respondent (data entry

and review and certification).

Program director: (2 hours @ 28.88 per hour) = $ 57.76

Administrative staff: (14 hours @ 13.14 per hour) = $183.96

 Average Cost per Grantee = $241.72

Across all grantees, the total cost to respondents is as follows:

1,300 grantees per year x $241.72 = $314,236

 x 1 year__

Total for 2015 = $314,236 

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).

There are no start-up costs or annual operational costs associated with this application.

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.

Additional cost estimates for maintenance, technical assistance and report review are as 

follows:
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Tasks for 2015:

Review Reports: 

1,300 grantee reports @ 1 per .30 hours = 650 hours

5 staff @ $35/hour = $175/hour Total = $113,750

Total for 2015 = $436,060

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 

of the OMB Form 83-I.

We developed a new form that collects program-specific data which support the mission of 

the Formula grant program. Accordingly, departmental staff will need to review the data 

collection.

16. For collections of information whose results will be published, outline plans for 

tabulation and publication.

Results of the information collected will not be published.

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.

Such approval is not being requested.

18. Explain each exception to the certification statement identified in Item 20, 

“Certification of Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the certifications.