1

EDICS Tracking and OMB Number Revised: 04/10/2015

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 319 (84.031X) 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

(http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html).

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 U.S. Department of Education 

(Department) for the purpose of obtaining programmatic and budgetary information needed to evaluate 

applications and to make funding decisions 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 submit their applications using the government-wide 

Grants.gov system. The applications transfer to the Department’s G5 system. Program staff use the G5 

 

1

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

EDICS Tracking and OMB Number Revised: 04/10/2015

RIN Number: XXXX-XXXX (if applicable)

system to set up the panels for the competitive reading, and the peer reviewers will use G5 to read and 

score the applications. 

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.

Information submitted in this application is unique to each respondent; 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;
3

EDICS Tracking and OMB Number Revised: 04/10/2015

RIN Number: XXXX-XXXX (if applicable)

 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 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 
4

EDICS Tracking and OMB Number Revised: 04/10/2015

RIN Number: XXXX-XXXX (if applicable)

the pledge of confidentiality should be provided.2If 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.

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 

 

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)
5

EDICS Tracking and OMB Number Revised: 04/10/2015

RIN Number: XXXX-XXXX (if applicable)

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 2,000 annually. We estimate 50

respondents at 40 hours per response. Applications will be submitted electronically. Labor costs for data 

processing and generation of application in required format are $100.00. Annual costs to applicant to file 

and maintain application materials are $100.00.

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 preOMB 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) : 

____________________
6

EDICS Tracking and OMB Number Revised: 04/10/2015

RIN Number: XXXX-XXXX (if applicable)

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

Cost to the Federal Government

A professional staff member to develop and revise 

clearance package (GS-12 employee: 80 hrs. @ 

$42.00 per hour

$3,360

GS-15/1 ($59.00 x 16 hours) employee for final 

review and approval.

$944

Estimated Total $4,304

Cost for Federally-supervised review of applications 

– Estimate of 50 applications

Readers reviewing applications @ 10 apps. per panel,

3 readers per panel, 5 panels (Total of 15 readers @ 

$1,100 each)

$16,500

Processing applications – staff. (1 staff x 40 hours x 

$42.00 per hour = $1,680)

(Overhead cost: $1,680 x 50 percent = $840)

$2,520

Contractor logistical support for workshops, 

application processing, field reading and slate 

preparation. 

$36,000

Staff time for conducting supervised review. (2 week 

review x 1 staff to chair each panel); (5 staff x 80 

hours = 400 hours x $40 per hour = $16,000)

(Overhead cost: $16,000 x 50 percent = $8,000)

$24,000

Staff time to review and approve funding 

recommendation.

(9 awards x 1 hour per award x $42 per hour = $378)

(Overhead cost: $378 x 50 percent = $189)

$567

Staff time to generate, approve, and issue grant 

awards. 

(2 hours per award x 9 awards = 18 hours)

(1 staff x $42.00 per hour x 18 hours = $756.00)

(Overhead cost: $756 x 50 percent - $378)

$1,134
7

EDICS Tracking and OMB Number Revised: 04/10/2015

RIN Number: XXXX-XXXX (if applicable)

Total Estimated Cost to Government (competition 

year)

$85,025

Annual Monitoring Cost

(19 hours per award x 9 awards = 171 hours)

(1 staff x $42.00 x 171 hours = $7,182

$7,182

Overhead cost: ($7,182 x 50 percent = $3,591) $3,591

Total Annual Government Estimated Cost $95,798

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).

By definition, since this is a reinstatement, all burden hours are new and considered a program change.

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.

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

Paperwork Reduction Act.

There are no exceptions to this certification statement.