SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

INVESTING IN INNOVATION (i3) GRANT PROGRAM

Justification:

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

The Investing in Innovation (i3) Fund was established under section 14007 of the 

American Recovery and Reinvestment Act of 2009 (ARRA). Since this is a 

competitive program, the Department needs to collect applications in order to 

determine which eligible applicants should receive a grant award. The Department 

will make three types of awards under this program: Scale-up Grants, Validation

Grants, and Development Grants. These grants will provide funding to support local 

educational agencies (LEAs), and nonprofit organizations in partnership with one or 

more LEAs or a consortium of schools to apply for funding to expand and develop 

innovate practices that can serve as models of best practices; allow eligible entities to 

work in partnership with the private sector and the philanthropic community; and 

identify and document best practices that can be shared and taken to scale based on 

demonstrated success. 

2. Indicate how, by whom, and for what purpose the information is to be used.

The information provided in the application will allow field readers and the 

Department of Education to determine if applicants are eligible and identify which 

applications qualify for funding. An additional part of the application consists of 

assurances regarding the applicant's compliance with applicable Federal laws and 

regulation in 34 CFR 76.132.

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.

Applicants are required to submit applications electronically to the U.S. Department 

of Education. 

All applicants are currently required to submit their applications electronically

through Grants.gov. 

4. Describe efforts to identify duplication. 

The information supplied by the applicant is not contained in any other data 

collection, and is unique to this program and the particular grantee. The application is 

a single document intended to serve a specific authorized purpose, and is in keeping 

with statutory requirements in 34 CFR 75.100.
5. If the collection of information impacts small businesses or other small entities, 

describe any methods used to minimize burden.

Small businesses are not impacted by this data collection.

6. Describe the consequences to Federal program or policy activities if the 

collection is not conducted or is conducted less frequently

The Department cannot distribute these grant awards to recipients without an 

application requesting the funds. If no application information were collected, the 

Department would not know which organizations want or merit funding.

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

be conducted in a manner inconsistent with 5 CFR 1320.5.

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

manner inconsistent with the guidelines in 5 CFR 1320.5.

8. 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.

The Department has consulted with potential applicants, other interested 

organizations and entities to obtain their views on the availability of possible 

requested information and potential application processes for these grants. The 

Department published a 60-and 30-day Federal Register Notice with no comments. 

 

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

renumeration of contractors or grantees.

No gifts or payments will be made to application respondents other than the award to 

the grant recipient.

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

for the assurance in statute, regulations, or agency policy.

There are no assurances of confidentiality provided to respondents.

11. Provide additional justification for any questions of a sensitive nature
There is no question of sensitive nature in this collection of information.

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

OII received approximately 1700 applications for the 2010 i3 grant competition. We 

originally anticipated that we would receive 2700 applications for the i3 grant 

therefore; OII has adjusted the expected applications to reflect the amount actually

received and to account for the amount expected each year of the three year renewal. 

Although OII received approximately 1700 applications, OII has determined that for a 

three year renewal ED should account for an increase of 100 applications per year to 

reflect the expected 2000 applications.

During the FY2012 competition the decision was made to re-structure the 

Development competition to allow for an annual pre-application phase. This resulted

in an increase in the number of applications received but it will ultimately decrease 

the net burden for all respondents. The following breakdown below details the change 

in burden.

Scale-up Grants:

Estimated data burden for Scale-up grants:

Annual reporting burden per response (preparing and submitting application):

120 hours x 100 applicants = 12,000 hours

Estimated respondent cost for Scale-up grants:

Estimated respondent cost for an application is based on 120 hours per application for 

Scale-up grants. The figure of 120 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 120 hours = $3000.

We expect to receive a total of 100 applications from eligible applicants. Total 

estimated cost for Scale-up grants: $3000 x 100 applications = $300,000

Validation Grants: 

Estimated data burden for Validation grants:
Annual reporting burden per response (preparing and submitting application):

120 hours x 400 applicants = 48,000 hours

Estimated respondent cost for Validation grants:

Estimated respondent cost for an application is based on 120 hours per application for

Validation grants. The figure of 120 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 120 hours = $3000.

We expect to receive a total of 500 applications from eligible applicants. Total 

estimated cost for Validation grants: $3000 x 400 applications = $1,200,000

Development Grants: 

Estimated data burden for Development Pre-Application grants:

Annual reporting burden per response (preparing and submitting application):

30 hours x 1500 applicants = 45,000 hours

Estimated respondent cost for Development Pre-Application grants:

Estimated respondent cost for an application is based on 30 hours per application for 

Development grants. The figure of 30 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 30 hours = $750.

We expect to receive a total of 1500 applications from eligible applicants.

Total estimated cost for Development Pre-Application grants: $750 x 1500

applications = $1,125,000

Estimated data burden for Development grants:

Annual reporting burden per response (preparing and submitting application):

60 hours x 200 applicants = 12,000 hours

Estimated respondent cost for Development grants:

Estimated respondent cost for an application is based on 60 hours per application for 

Development grants. The figure of 60 hours is based on our own experience and 

comments from eligible applicants that we consulted. 
We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 60 hours = $1500.

We expect to receive a total of 200 applications from eligible applicants.

Total estimated cost for Development grants: $1500 x 200 applications = 

$300,000

Grand total for all (i3) grants:

Estimated overall data burden for all grants:

Annual reporting burden per response (preparing and submitting application):

Scale-up grants: 120 hours x 100 applicants = 12,000 hours

Validation grants: 120 hours x 400 applicants = 48,000 hours

Development Pre-Application grants: 30 hours x 1500 applicants = 45,000 hours

Development grants: 60 hours x 200 applicants = 12,000 hours

Total: 2200 applicants and 117,000 hours

Estimated overall cost burden for all grants:

Estimated cost for Scale-up grants: $3000 x 100 applications = $300,000

Estimated cost for Validation grants: $3000 x 400 applications = $1,200,000

Estimated cost for Development Pre-Application grants: $750 x 1500 applications 

=$1,125,000

Estimated cost for Development grants: $1500 x 200 applications = 

$300,000

Total: $2,925,000

13. Provide an estimate of the total annual cost burden to respondents or record 

keepers resulting from the collection of information. 

There are no startup costs to respondents.

14. Estimated annualized Federal cost:

There will be at least10 program personnel dedicated solely to the i3 program along

with an assigned contractor therefore $2,925,000 will be the estimated annual 

Federal cost. It was originally anticipated that ED would receive 2700 applications 

for the i3 grant with an estimated annualized Federal cost of $4,950,000 however;
the proposed changes to the structure of the Development competition will reduce 

the estimated annualized Federal cost by $2,025,000 to $2,925,000. 

Scale-up Grants:

 Estimated data burden for Scale-up grants:

Annual reporting burden per response (preparing and submitting application):

120 hours x 100 applicants = 12,000 hours

Estimated respondent cost for Scale-up grants:

Estimated respondent cost for an application is based on 120 hours per application for 

Scale-up grants. The figure of 120 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 120 hours = $3000.

We expect to receive a total of 100 applications from eligible applicants. Total 

estimated cost for Scale-up grants: $3000 x 100 applications = $300,000

Validation Grants: 

Estimated data burden for Validation grants:

Annual reporting burden per response (preparing and submitting application):

120 hours x 400 applicants = 48,000 hours

Estimated respondent cost for Validation grants:

Estimated respondent cost for an application is based on 120 hours per application for

Validation grants. The figure of 120 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 120 hours = $3000.

We expect to receive a total of 500 applications from eligible applicants. Total 

estimated cost for Validation grants: $3000 x 400 applications = $1,200,000

Development Grants: 
Estimated data burden for Development Pre-Application grants:

Annual reporting burden per response (preparing and submitting application):

30 hours x 1500 applicants = 45,000 hours

Estimated respondent cost for Development Pre-Application grants:

Estimated respondent cost for an application is based on 30 hours per application for 

Development grants. The figure of 30 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 30 hours = $750.

We expect to receive a total of 1500 applications from eligible applicants.

Total estimated cost for Development grants: $750 x 1500 applications = 

$1,125,000

Estimated data burden for Development grants:

Annual reporting burden per response (preparing and submitting application):

60 hours x 200 applicants = 12,000 hours

Estimated respondent cost for Development grants:

Estimated respondent cost for an application is based on 60 hours per application for 

Development grants. The figure of 60 hours is based on our own experience and 

comments from eligible applicants that we consulted. 

We estimate respondent cost at an average of $25 per hour so that the average cost 

per application would be $25 x 60 hours = $1500.

We expect to receive a total of 200 applications from eligible applicants.

Total estimated cost for Development grants: $1500 x 200 applications = 

$300,000

Grand total for all (i3) grants:

Estimated overall data burden for all grants:

Annual reporting burden per response (preparing and submitting application):

Scale-up grants: 120 hours x 100 applicants = 12,000 hours

Validation grants: 120 hours x 400 applicants = 48,000 hours

Development Pre-Application: 30 hours x 1500 applicants = 45,000 hours
Development grants: 60 hours x 200 applicants = 12,000 hours

Total: 2200 applicants and 117,000 hours

Estimated overall cost burden for all three grants:

Estimated cost for Scale-up grants: $3000 x 100 applications = $300,000

Estimated cost for Validation grants: $3000 x 400 applications = $1,200,000

Estimated cost for Development Pre-Application grants: $750 x 1500 applications 

=$1,125,000

Estimated cost for Development grants: $1500 x 200 applications = 

$300,000

Total: $ 2,925,000

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

13 or 14

There is a program change decrease of -33,000 total annual burden hours and an 

increase of +200 respondents. The collection document maintains the original scope, 

the questions asked have not changed, and the criteria, have been reduced to reflect 

the criteria specifically designated for the pre-application phase. During the 

FY2013and future competitions, applicants will be asked to submit an abbreviated 

version of the application, and as a result of these less stringent application 

requirements we anticipate an increase in the number of respondents, which will 

increase the burden. However following the initial review process, only entities that 

have submitted pre-applications that are scored highly by the peer reviewers will be 

invited to submit full applications, but other pre-applicants may submit full 

applications if they wish. Based upon the small number that will be invited to submit 

a full application, we anticipate a significant decrease in the burden as it is currently 

calculated, and we do not anticipate many pre-applicants who were not highly scored 

to submit full applications.

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

tabulation and publication.

The Department will make the following available to the public on the Department’s i3 

Web site: 

 A list of all applicants and their partners; the type of grant for which the 

applicant applied; and the requested budget, including the amount of funds 

requested for each partner; 

 All Scale-up applications with personally identifiable information and 

proprietary information identified by the applicant redacted; 
 All successful Validation and Development applications with personally 

identifiable information and proprietary information identified by the 

applicant redacted; and 

 Peer reviewer scores and comments (TRFs) for all successful applications. 

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.

The expiration date will be displayed on the information collection.

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

"Certification for Paperwork Reduction Act Submissions form”

There is no exception to the “Certification for Paperwork Reduction Act 

Submissions”