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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

Annual Performance Report for Grants under the 

Talent Search Program

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.

The Department of Education (Department) is requesting approval of an extension 

without change for the Talent Search (TS) Annual Performance Report (APR) form to 

collect annual performance data from projects funded by Talent Search (TS) program 

grants. The TS APR is administered in accordance with the Education Department 

General Administrative Regulations (EDGAR) as modified by the Uniform Guidance 2 

CFR 200. 

The TS program provides Federal financial assistance in the form of discretionary grants 

to: (a) institutions of higher education; (b) public and private agencies and organizations 

including community-based organizations with experience in serving disadvantaged 

youth; (c) secondary schools; and (d) combinations of such institutions, agencies and 

organizations. The specific goal of the TS program is to help youth from disadvantaged 

backgrounds complete secondary education and enroll in and complete programs of 

postsecondary education; and to publicize the availability of, and facilitate the application 

for, student financial assistance for persons who seek to pursue postsecondary education

(20 U.S.C. 1070a–12).

The information that grantees submit in the APR allows the Department to annually 

assess each grantee's progress in meeting their project's approved goals and objectives. 

The APR data are compared with the project’s approved objectives to determine the 

project’s accomplishments, to make decisions regarding whether funding should be 

continued, and to award prior experience points. The regulations for this program 

provide for awarding up to 15 points for prior experience (34 CR 643.22). During a 

 

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Please limit pasted text to no longer than 3 paragraphs.
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

competition for new grant awards, the prior experience points are added to the average of 

the field reader scores to arrive at a total score for each application. Funding 

recommendations and decisions are primarily based on the rank order of applications on 

the slate; therefore, assessment of prior experience points, based on data in the annual 

performance report, is a crucial part of the overall application process.

Further, this performance report form is the main source of data for the Department's 

response to the requirements of the Government Performance and Results Act (GPRA) 

for this program. 

The Department collects information from TS grantees under the authority of Title IV, 

Part A, Subpart 2, Division 1, Sections 402A-402B of the Higher Education Act of 1965, 

as amended, the program regulations in 34 CFR 643, and the Education Department 

General Administrative Regulations (EDGAR), in 34 CFR 74.51, 75.720, and 75.732. 

The authorizing statute, as amended in 2008 by the Higher Education Opportunity Act, 

which is the basis for the current program regulations, can be found at the following 

URL: http://www2.ed.gov/programs/triotalent/legislation.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.

The Department uses the data collected to (a) evaluate projects' accomplishments; (b) 

determine the number of prior experience points to be awarded to current grantees; and 

(c) aid in compliance monitoring (i.e., to determine whether grantees are in compliance 

with the selection requirements for project participants [34 CFR 643.3]). 

In addition, the Department uses the annual performance reports to produce programlevel data for annual reporting, budget submissions to OMB, Congressional hearings and 

inquiries, and responding to inquiries from higher education interest groups and the 

general public.

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 data collection method allows the grantees to use computerized data systems to 

collect, retrieve, and report the requested information. A Web-based software application 

has been developed for grantees to enter the data online and submit the entire report via 

the Internet. The TS projects have been submitting the annual performance report via the 

Internet since 1998. 

The data collected are in aggregate form at the program level, not data on individual 

participants; thus the reports are a low-level security risk. Nonetheless, the Web site is 
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

secured to ensure that the data are seen only by authorized individuals and are protected 

from network hackers. Further, online data edits are in place to ensure the accuracy and 

integrity of the data submitted.

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.

Since the information grantees submit in their performance reports is unique to each 

project and is not collected elsewhere, no duplication exists. No other instrument is 

available to collect the information that the program needs to assess prior experience or 

program outcomes. The data collected in the annual performance reports are 

fundamental to these programs.

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 information collection does not affect 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.

The collection of performance reports is required annually. Collection of information on 

a less frequent basis is not feasible. These reports are used to determine if the grantee is 

making satisfactory progress in meeting the goals and objectives proposed in its initial 

grant application. In addition, the information is needed to award prior experience points 

to grantees. Without this data collection, the Department would not have the data to 

assess the prior experience provision of the authorizing statute, respond to the GPRA and 

other program performance and efficiency measures, or develop improved policies for 

program administration.

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;
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

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 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 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.

The only special circumstance that applies to this collection is the need to retain records 

for more than three years. Talent Search has one standardized objective (high school 

graduates that complete a course of postsecondary education within six years) that has a 

six year benchmark for reporting with regards to projects that are successful in two 

consecutive Talent Search grant competitions. Therefore, reporting requirements in 

connection with this objective will extend beyond a three year period.

No other special circumstances apply to this collection. 

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.

Department staff members have attended a number of state, regional, and national 

meetings at which the Department solicited informal views and comments on reporting 

requirements from grantees and other interested persons. A separate 60-day Federal 
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

Register notice followed by a 30-day Federal Register notice will be published to solicit 

public comment on the APR form.

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 payment 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 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.

No assurances of confidentiality are provided to the respondents. The Department makes 

no pledge about the confidentiality of the data.

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 performance report form does not include questions about sexual behavior and 

attitudes, religious beliefs, or other matters that are commonly considered sensitive and 

private.

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 

 

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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)
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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 contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

Estimated burden hour for this collection of information is 7,200. We estimate approximately

450 respondents. The performance reports are submitted annually.

Number of 

Respondents

Estimated 

Preparation Time, 

per respondent

Total Estimated 

Burden Hours

Public Sector 323 16 hours 5,168 hours

Private Sector 127 16 hours 2,032 hours

Total estimated 

burden hours 450 16 hours 7,200 hours

(Estimated burden: 7,200 hrs. Total number of hours (preparation time) multiplied by the total 

number of respondents equals estimated burden hours). Preparation time includes 14 hours for 

professional staff to gather the information using computerized technology and 2 hours for

clerical staff to enter the data into the Web-based form.

Professional staff

(450 respondents X 14 hours X $35 per hour) $220,500

Clerical staff

(450 clerical staff members X 2 hours X $18 per hour) $16,200

Total estimated cost to all respondents $236,700

Note: As many of the respondents are project staff whose salaries are largely financed with 

Federal grant funds, the Department believes that the actual cost to respondents is lower than 

those indicated above but cannot provide an accurate estimate at this time. 
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

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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 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 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. 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) : 

____________________

Total Annualized Costs Requested : 

There are no other costs to the respondents associated with this information collection. 

Grantees are required by program regulations to collect and maintain this information. 

The costs to transmit the data electronically via the Web are customary and usual 

business practices.

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.
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

The largest portion of the Government's cost is borne directly by the Department of 

Education in designing the report form, securing clearance of the form, and collecting, 

aggregating, and disseminating the information.

Designing performance report form 

120 hours at $40 per hour

Overhead (est. at 50%): 120 times $20

$7,200

Clearing performance report

120 hours at $40 per hour

Overhead (est. at 50%): 120 times $20

$7,200

Annual updates to Web application, Web site hosting, 

help desk, and data processing (contractor’s costs) $80,000

Analyses of data and preparation of national 

summary reports and individual project data 

(contractor’s costs)

$90,000

Professional staff to review and edit reports for 

dissemination

160 hours at $40 per hour

Overhead (est. at 50%): 160 times $20

$9,600

TOTAL FEDERAL COST $194,000

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).

The number of respondents has decreased from 461 down to 450 and the total burden 

hours have decreased from 7,376 to 7,200 over the past grant cycle. The decrease in the 

number of projects funded is a result of grantees not reapplying or having been 

unsuccessful in the most recent Talent Search grant competition, as well as grantees 

relinquishing the TS grant award or not receiving a continuation award for not making 

annual substantial progress as required by the program statute and regulations. 

Therefore, the number of projects currently completing the Talent Search APR is 450 

grantees.

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 
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

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schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

Collected information will be analyzed annually to determine if each grantee is meeting 

its approved goals and objectives and to award prior experience points. Program 

performance and efficiency measures, based on data conveyed in grantees' annual 

performance reports, are disseminated in the Department's Annual Program Performance 

Plan. In addition, the Department's Web site provides data on performance and 

efficiency measures, beginning with the 2007–08 performance period, at the grantee 

level; this more detailed reporting has been made possible due to improvements in 

accuracy resulting from incorporating the standard objectives into the report form.

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.

This report form and the Web site will display the expiration date for OMB's approval of 

the information collection.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

34 CFR 643.22(d)(6) of the TS program regulations require TS grantees to track postsecondary

enrollees’ postsecondary attainment status over the course of six years as part of the 

Postsecondary Attainment objective. TS projects may either track all postsecondary enrollees or 

a random sample of them, as outlined in “Appendix: Guidance on Determining Appropriate 

Sample Size and Random Sampling to Track Students for Postsecondary Attainment Objective” 

in the TS APR Instructions.