# Early Reading First: Grant Performance Report
Office of Management and Budget: Clearance Packag e, Supporting Statement and Data Collection Instrument2

EDICS Tracking and OMB Number: ( 04940 ) 1810

- 0696 Revised: 09/21/2012 RIN Number: N/A 

## Supporting **Statement for**  **Paperwork Reduction Submission**

**Early Reading First Performance Report** U.S. Department of Education EDICS Tracking and OMB Number: ( 04940 ) 1810

- 0696

Revised : 09/21/2012 RIN Number: N/A

**A. JUSTIFICATION**  **1. Explain the circumstances that m**  **ak e the collection of inform**  **ation necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each**  **statute and regulation m andating or authorizing the collection of inform**  **ation** Each Early Reading First grantee is required to forw ard an annual performance report or final report to the Secretary describing the annual progress made tow ards the project’s goals. The Elem entary and Secondary Education Act (ESEA) of 1965, as ame nded **,** Title I, Part B, Subpart 2 Early Reading First (ERF), s ection 1225 states that

“ Each eligible applicant receiving a grant under this subpart shall report annually to the Secretary regarding the eligible applicant's progress in addressing the purposes of this subpart. Such report shall include, at a minimum, a description of

— (1) the research

- based instruction, materials, and activities being used in the programs funded under the grant;(2) the types of programs funded under the grant and the ages of c hildren served by such programs;(3) the qualifications of the program staff who provide early literacy instruction under such programs and the type of ongoing professional development provided to such staff; and(4) the results of the evaluation described i n section 1222(b)(9). ” In addition, section **§ 74.51 of** Education Department General Administrative Regulations (EDGAR) states that,

“ (a) Recipients are responsible for managing and monitoring each project, program, subaward, function, or activity supported by the award. Recipients shall monitor subawards to ensure subrecipients have met the audit requirements in §74.26. (b) The Secretary prescribes the frequency with which the performance reports shall be submitted. Except as provided in §74.51(f), perfor mance reports are not required more frequently than quarterly or, less frequently than annually. Annual reports are due 90 calendar days after the grant year; quarterly or semi

- annual reports are due 30 days after the reporting period. The Secretary may re quire annual reports before the anniversary dates of multiple year awards in lieu of these requirements. The final performance reports are due 90 calendar days after the expiration or termination of the award.3 (c) If inappropriate, a final technical or pe rformance report is not required after completion of the project. (d) When required, performance reports must generally contain, for each award, brief information on each of the following: (1) A comparison of actual accomplishments with the goals and obje ctives established for the period, the findings of the investigator, or both. Whenever appropriate and the output of programs or projects can be readily quantified, this quantitative data should be related to cost data for computation of unit costs.(2) Rea sons why established goals were not met, if appropriate.(3) Other pertinent information including, when appropriate, analysis, and explanation of cost overruns or high unit costs. (e) Recipients are not required to submit more than the original and two c opies of performance reports. (f) Recipients shall immediately notify the Secretary of developments that have a significant impact on the award

- supported activities. Also, notification must be given in the case of problems, delays, or adverse conditions w hich materially impair the ability to meet the objectives of the award. This notification must include a statement of the action taken or contemplated, and any assistance needed to resolve the situation. (g) The Secretary may make site visits, as needed. (h) The Secretary complies with the clearance requirements of 5 CFR part 1320 when requesting performance data from recipients. ” The Department is requesting to renew the Early Reading First Performance Report.

**2. Indicate how, by whom**  **, and for what purpose the inform**  **ation is to be used. Except for a new collection, indicate the actual use the agency has m**  **ade of the information received from the current collection.**  This information will be collected from approximately 60 grantees in calendar year 2 012 and approximately 30 grantees in calendar year 2013 e ERF statute requires all funded projects to report annually to the Department documenting project’s progress tow ards accomplishing its goals and objectives. The Department has used this information to m onitor grantees and examine outcomes across funded projects. See Appendix D for a copy of the data collection instrument we propose to renew
. **3. Describe whether, and to what extent, the collection of inform**  **ation involves the use of autom ated,**  **el ectronic, m**  **echanical, 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 inform**  **ation technology to reduce burden.** The respondents have the option of filling out a Microsoft Word document electronically and can return this form via e mail or printed out in hard copy and mailed to ED

. An electronic document reduces costs of printing and makes the process of data collection more efficient. **4. Describe efforts to identify duplication. Show specifically why any sim**  **ilar information already available cannot be used or m**  **odified for use of the purposes described in Item 2 above.** 4 There are no other sources collecting the same data. The ERF performance report is the sole source of information collection for the ERF program. The document serves to streamline the data collection process by creating a single form for all ent ities. **5. If the collection of inform**  **ation impacts small businesses or other small entities (Item 8b**  **of IC Data Part**  **2), describe any m ethods used to m**  **inimize burden.** This collection of information does not impact small businesses

. Under EDGAR regulat ions, requirements for small entities are minimized. **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 burde**  **n.** The Elementary and Secondary Education Act (ESEA) of 1965, as amended **,** Title I, Part B, Subpart 2 Early Reading First (ERF), s ection 1225 requires all funded applicants to report to the Secretary annually. T he performance report is used on an annual bas is as one of the methods of monitoring whether grantees have made substantial progress tow ards project goals as stated in approved applications. Without it, there is no w ay to document sufficient progress annually. **7. Explain any special circumstance**  **that would cause an inform ation collection to be conducted in a**  **manner:**  **requiring respondents to report inform ation to the agency m**  **ore often than quarterly;**  **requiring respondents to prepare a written response to a collection of inform ation in fewer than 3**  **0 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, m edical, governm**  **ent contract, grant -**  **in**   ** aid, or tax records for m** **ore than three yea rs;**   **in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;**   **requiring the use of a statistical data classification that has not been reviewed and approved by OM**  **B;**  **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 o f data with other agencies for com**  **patible confidential use; or**   **requiring respondents to submit proprietary trade secrets, or other confidential inform ation unless**  **the agency can dem onstrate that it has instituted procedures to protect the inform**  **ation's con**  **fidentiality to the extent permitted by law.** None of the special circumstances listed apply to this data collection. **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 inform**  **ation collection prior to submission to OMB. Summ**  **arize 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 reporti**  **ng form at (if any),**  **and on the data elem ents to be recorded, disclosed, or reported.** 5

**Consultation with representatives of those from whom** **inform ation is to be obtained or those who m**  **ust com** **pile records should occur at least once every 3 years -**  **even if the collection of inform**  **ation activity is the same as in prior periods. There m**  **ay be circumstances that m ay preclude consultation in a specific situation.**  **These circumstances should be explained.** The 60 day notice was published on September 28, 2012 (77 FR 59597). T he 30

- day federal register notice wa s published

. **9. Explain any decision to provide any paym**  **ent or gift to respondents, other than renumeration of contractors or grantees.**  Respondents will not be provided any payments or gifts for data collect ion. **10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in**  **statute, regulations, or agency policy.** ED is not requesting any confidential information and as such, no assurances of confidentiality are neces sary. **11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and**  **attitudes, religious beliefs, and other m atters that are commonly considered private. This justification should**  **include the reasons why the age ncy considers the questions necessary; the specific uses to be m**  **ade of the inform**  **ation, the explanation to be given to persons from whom** **the inform ation is requested, and any steps to**  **be taken to obtain their consent.** This data collection does not have any questions of a sensitive nature for matters that are commonly considered private. **12. Provide estim**  **ates of the hour burden of the collection of inform ation. The statement should:**  **Indicate the number of respondents, frequency of response, annual hour bur den, and an explanation of how**  **the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain inform**  **ation on which to base hour burden estimates. Consultation with a sam ple (fewer than 10) of potential**  **responden ts is desirable. If the hour burden on respondents is expected to vary widely because of differences**  **in activity, size, or com plexity, show the range of estim**  **ated hour burden, and explain the reasons for the variance. Generally, estim**  **ates should not incl ude burden hours for custom**  **ary and usual business practices. If this request for approval covers m**  **ore than one form , provide separate hour burden estim**  **ates for each form** **and aggregate the hour burdens in Item 16 of IC Data Part 1. Provide estim**  **ates of ann ualized cost to respondents of the hour burdens for collections of inform**  **ation, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties**  **for inform ation collection activities should not be included here**  **. Instead, this cos t should be included in Item**  Total Annual Burden Hour calculation for the Early Reading First Performance Report: 1,020 total burden hours per y ear. ED estimates that over the two ye ars, approximately 90 Early Reading First grantees w ill be required to use Early Reading First performance report either as an annual or final performance report. Ap proximately 30 grantees will use this form as an annual performance report and approximately 60 will use this form as a final performance report. The annual burden hours per response is estimated to average 22 hours for annual performance reports and reflects the estimated time grantees spend reporting on project progress and performance and addressing administrative requirements.6 The annual b urden hours per response is estimated to average 23 hours for final performance reports and reflects the estimated time grantees spend reporting on project progress and performance and addressing administrative requirements. It is estimated that it will ta ke respondents slightly longer to complete the final performance report than the annual performance report because the Early Reading First final performance requires respondents to provide additional summary information for the entire project period relati ng to project impact and success. The burden hour averages for annual and final performance report respondents listed above are based on the time it has taken grantees previously to respond to the ERF performance report
. **Total Burden Hour Calculations f**  **or the ERF Perform**  **ance Report :**  Burden Hours for ERF performance report when Used as an Annual Performance Report: 22 hours/response X 30 responses = 660 total burden hours. Burden Hours for ERF performance report when Used as a Final Performance Report: 23 hours/response X 60 responses = 1380 total burden hours Total Burden Hours for ERF performance report : 660 burden hours (annual performance report) + 1380 burden hours (final performance report) = 2040 total annual burden hours over tw o years . T he annual burden hours for the ERF Performance report is 2040 hours/2 years = **1020 hours/year**

. Total Cost Burden to Respondents for the ERF performance report2040 total burden hours x $ 3 7 /hour = $ 75,480

. The annual cost burden to respondents for the ERF performance report is $75,480/2 years = **$37,740/year**

. **13. Provide an estim**  **ate of the total annual cost burden to respondents or record keepers resulting from the**  **collection of inform**  **ation. (Do not include the cost of any hour burden shown in Items 12 and 14.)**  **The cost estimate should be split into two com ponents: (a) a total capital and start**  **- up cost com**  **ponent (annualized over its expected useful life); and (b) a total operation and m**  **aintenance and purchase of services com** **ponent. The estim ates should**  **take into account costs associated with generating, m aintaining, and**  **disclosing or providing the inform ation. Include descriptions of m**  **ethods used to estimate major cost factors including system and technology acquisition, expected useful life of capital**  **equipm ent, the discount rate(s),**  **and the tim e period over which costs will be incurred. Capital and start**  **- up costs include, am**  **ong other items, preparations for collecting inform**  **ation such as purchasing com puters and software; monitoring, sampling,**  **drilli ng and testing equipment; and record storage facilities.** 
**If cost estim ates are expected to vary widely, agencies should present ranges of cost burdens and explain the**  **reasons for the variance. The cost of contracting out inform ation collection services s**  **hould be a part of this cost burden estim**  **ate. In developing cost burden estim ates, agencies m**  **ay consult with a sam ple of**  **respondents (fewer than 10), utilize the 60 -**  **day pre -**  **OMB submission public comment process and use existing econom**  **ic or regulatory im pa**  **ct analysis associated with the rulemaking containing the inform ation collection,**  **as appropriate. Generally, estimates should not include purchases of equipment or services, or portions thereof, m**  **ade: (1) prior to October 1, 1995, (2) to achieve regulator**  **y com pliance with requirem**  **ents not associated with the inform**  **ation collection, (3) for reasons other than to provide inform ation or keep records for the governm**  **ent, or (4) as part of custom**  **ary and usual business or private practices.**
This collection has n o start
- up costs.7

**14. Provide estim**  **ates of annualized cost to the Federal governm ent. Also, provide a description of the**  **method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, prin**  **ting, and support staff), and any other expense that would not have been incurred without this collection of inform**  **ation. Agencies also may aggregate cost estim ates from** **Ite ms 12, 13, and 14**  **in a single table.** Total Cost to the Federal Government for ERF Performance Report : $ 11,100 The total annual cost is based on the following: ERF Performance Report as Annual Performance Report: 3 hours per response x 30 responses x $3 7 / hour (GS

- 1 3 hourly rate) = $ 3,330 ERF Performance Report as Final Performanc e Report: 3.5 hours per response X 60 responses X $3 7 /hour (GS

- 1 3 hourly rate) = $ 7,770 This cost is distributed over two years. The annual cost is $11,100/2 years = **$5,550/year. 15.**  **Explain the reasons for any program changes or adjustments reporte**  **d in Item 16 of IC Data Part 1.** The estimated annual burden hours resulted in an adjustment reducing burden by 1,985 hours due to the fact that we have fe wer grantees that will need to submit these performance reports this year. When w e last sought appro val for this collection, w e had 133 estimated grantees that would be responding annually. Currently we have 60 grantees that still need to submit annual performance reports also resulting in an adjustment of 75 responses. All other grantees have complete d their projects and already submitted their final reports. **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 ti me**  **schedule for the entire project, including beginning and ending dates of the collection of inform**  **ation, com pletion of report,**  **publication dates, and other actions.** There are no plans to formally publish the results of this data collection. Rather, the data obtained through this data collection will be used by the program office to monitor the funded ERF grantees and inform GPRA results for the program. **17. If seeking approval to not display the expiration date for OMB approval of the inform**  **ation coll ection,**  **explain the reasons that display would be inappropriate.** Program is not seeking approval to not display the expiration data for OMB approval. All data collection instruments will include the OMB expiration date. **18. Explain each exception to th**  **e certification statem ent identified in the "Certification for Paperwork**  **Reduction Act Submissions" Form .**  There are no exceptions to the certification statement identified in the “ C ertification for Paperwork Reduction Act Submissions” Form. **B. Collection**  **s of Inform ation Employing Statistical Methods.**  This data collection applies to ERF grantees. This tool will not employ any statistical methods.