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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 copy of the 

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

of information.

The collection of this information is part of the government–wide effort to improve the 

performance and accountability of all federal programs, under the Government Performance and 

Results Act (GPRA) passed in 1993. Under GPRA, a process for using performance indicators 

to set program performance goals and to measure and report program results was established. To 

implement GPRA, ED developed GPRA measures at every program level to quantify and report 

program progress required by the Elementary and Secondary Education Act of 1965, as amended, 

Title V, Part C. The GPRA program level measures for the Magnet Schools Assistance Program

(MSAP) are reported in the Annual Performance Report (APR). The APR is required under 

EDGAR §§ 74.51, 75.118, 75.590, and 80.40. The annual report provides data on the status of 

the funded project that corresponds to the scope and objectives established in the approved 

application and any amendments. Under EDGAR § 75.118, the report must provide the most 

current performance and financial information. On January 4, 2011, Congress passed the GPRA 

Modernization Act of 2010. The Act improves on the original GPRA of 1993 and modernizes the 

federal government’s performance management framework.

In previous MSAP grant cycles, grantees submitted GPRA data based on individual project 

formulations. This circumstance made it difficult to quantify and report the data accurately on 

MSAP’s overall performance. To ensure that accurate and reliable GPRA measure data are 

reported to Congress on program implementation and performance outcomes, MSAP wants to 

collect the raw data from grantees in a consistent format to calculate these data in the aggregate 

with the same mathematical procedures. 

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.

Data collection activities are designed to yield quantitative raw data that represents grantees 

program implementation and performance outcomes. This section details the data collection 

activities requiring clearance by the Office of Management and Budget. The information 

collected will be used to calculate MSAP’s performance for its GPRA measures and put the 

findings/outcomes into context. Exhibit 1 details the data collection instrument’s mode of 

administration, content, needed completion time, and estimated timeline for administration.
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Exhibit 1. Data Collection Instruments

Instrument/ 

Respondent group N

Mode of 

administration Content Time Timeline

GPRA 

Table/MSAP 

grantee school

116

MSAP 

schools

Data uploaded in 

MAPS system

with APR GPRA Data

30 minutes per 

MSAP school

September 

through 

October

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 of 

using information technology to reduce burden.

Currently, grantees submit their APRs using MAPS. The GPRA Table has been updated to 

reflect the evolution of past MSAP GPRA measures and the addition of new MSAP GPRA 

measures. The simultaneous submission of both APRs and GPRA data using a format and mode 

familiar to the grantees standardizes collection and reduces the burden faced by 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.

The APR data collected through the updated GPRA Table are not currently available or collected 

via the current OMB approved generic annual performance reporting forms. Therefore, the data 

collected via the updated GPRA Table will not cause a duplication of efforts. 

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

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

The program does not impact small businesses or other 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.

Grantees must submit the APR (EDGAR § 75.253). Without the data collection, ED could not 

report accurate and reliable GPRA data to Congress or approve continuation funding. The APR

provides data on the status of the funded project that corresponds to the GPRA measures 

established in the approved application and any approved amendments. 

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;
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 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 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 tht it has instituted procedures to 

protect the information’s confidentiality to the extent permitted by law.

There are no circumstances that require this information collection to be conducted in a manner 

inconsistent with any of the conditions outlined under A.7 of the special instructions for the 

justification.

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 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.

OII has held two feedback webinar discussions with less than nine grantees and consultants that 

allowed them to provide input on the GPRA forms. Based on the given feedback, adjustments 

were made to the forms to make them more user-friendly; these form adjustments do not change 

the amount of time to complete the MSAP tables. The Department published a 60-and 30-day

Federal Register Notice, we did not receive any public comments during the 60-day comment 

period. 

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

remuneration of contractors or grantees.

No payments or gifts to respondents were made and none are planned or contemplated.
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10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy.

There are no assurances of confidentiality.

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 data collection includes no questions of a sensitive nature.

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. 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 item 13 of OMB Form 83-I.

 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 not be included in Item 14.

The GPRA Table data collection will occur annually, the responding grantee’s estimated annual 

hour burden will remain 30 minutes per MSAP school. The total estimated annual hour burden 

will vary per grant project because the number of schools in each MSAP project varies. The 

2013 MSAP grant cohort has 116 schools, ranging from 1 to 7 magnet schools per project.

Exhibit 2 shows the estimated annual/total respondent burden for this data collection as 58 hours.

Exhibit 2. Respondent Hour Burden Estimate

Data Collection 

Activity

Hour Burden per 

Respondent (in 

hours)

Total Expected 

Number of 

Respondents

Total Hour Burden 

(in hours)

GPRA Table 0.50 116 58 hours
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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 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 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.

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : ____________________

Total Annualized Costs Requested : 

There are no costs that meet the criteria for inclusion under this item.

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.

Updating GPRA clearance package (10 hrs x $35/hr) = $ 350

Staff time for review (3 staff x 60 hours/staff x $35/hr) = $ 6,300

Cost of consultant/contractor to collect and analyze data = $ 50,000

Estimated total cost to the Federal government = $ 56,650
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15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of 

the OMB Form 83-I.

There is an adjustment decrease of -18.5 annual burden hours and a -37 decrease adjustment due 

to few schools receiving MSAP support. 

Annual Number of Responses: Thirty-seven fewer schools are receiving MSAP support under the

2013 competition. 

Annual Burden Hours: The estimated annual burden per MSAP school remains fixed at 30 

minutes; however, the number of respondents has decreased from 153 to 116. This results in an 

overall reduction of 18.5 annual burden hours for an estimated 58 annual burden hours for the 

2013 cohort.

Annual Cost Burden: The $56,650 figure reflects a $9,371 increase over the amount previously

approved. This net increase reflects both the contractor's increasing cost of doing business 

($9,721) and a slight decrease in the staff cost associated with the preparation of the GPRA 

clearance package (-$350).

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 for publication of the information.

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 are no plans to not display the expiration date of the OMB approval of the data collection.

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

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

There are no exceptions to the certification statement.