1

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 cop y 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 section 1

. Specify the review t ype of the collectio n (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y 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. Th e 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 yo uth; (c) secondary

schools; and (d) combinations of such institutions, agencies and o rganizations. 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 pr oject’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
1 Please limit pasted text to no longer than 3 paragraphs.2

EDICS Tracking and OMB Number: (XXXX) XXXX

- XXXX Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable) competitio n 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 primaril y 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 o f 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. T he authorizing statute, as amended in 2008 b y 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 c urrent 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 pro duce program

level 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 collecti on 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 me ans of collection. Also describe an y consideration given to using technology

to reduce burden. The data collection method allows the grantees to use computerized data s ystems to collect, retrieve, and report the requested information. A Web

- based softw are 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 f orm at the program level, not data on individual participants; thus the reports are a low

- level security risk. Nonetheless, the Web site is3

EDICS Tracking and OMB Number: (XXXX) XXXX

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- XXXX (if applicable) secured to ensure that the data are seen onl y b y authorized individuals and are protected from network hackers. Further, online data edits are in place to ensure the accuracy and integrit y of the data submitted. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the pur poses 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 meth ods used to minimize burden. A small entit y 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 th at 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 , count y, town, township, school district, or special district with a population of less than 50,000. This info rmation 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 frequentl y, as well as an y technical or legal obstac les 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 goa ls 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 provisio n 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 conduct ed in a manner:

 requiring respondents to report information to the agency more often than quarterl y;

 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;

 requiring respondents to s ubmit more than an original and two copies of any document;4

EDICS Tracking and OMB Number: (XXXX) XXXX

- XXXX Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable)

 requiring respondents to retain records, other than health, medical, government contract, grant
- in

- aid, or tax records for more than three y ears;

 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 b y 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 unnecessaril y i mpedes sharing of data with other agencies for compatible confident ial 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 ye ars . 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 bey ond a three ye ar period. No other special circumstances appl y to this collection. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 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 b y the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outsid e 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 an y), 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 y ears
– 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 Federal5

EDICS Tracking and OMB Number: (XXXX) XXXX

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- XXXX (if applicable) Registe r 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

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful ju stification

. The Department will not provide pay ment or gifts to respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy

. If personally

identifiable infor

mation (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality . I f ther e is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. No assurances of confidentiality are provided to the respondents. The Department makes no pledge about the confidential it y of the data. 11. Provide additional justification for an y 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 wh y t he 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 an y steps to be taken to obtain their consent. The performance report form does n ot 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 ty

pe (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 respons e, annual hour burden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to

2 Requests for this information are in accordance with the follow ing 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)6

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 widel y because of difference s in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, 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 ROCI S IC Burden Analy sis Table

. (The table should at minimum include Respondent types, IC activity , Responde nt and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outsi de 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 4 50 respondents. The performanc e reports are submitted annually

. Number of Respondents Estimated

Preparation Time, per respondent Total E stimated

B urden H ours Public Sector 3 23 16 hours 5, 168 hours Private Sector 1 27 16 hours 2,032 hours **Total estimated burden hours**  **4 50**  **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) $22 0,500 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 a t this time.7

EDICS Tracking and OMB Number: (XXXX) XXXX

- XXXX Revised: XX/XX/XXXX RIN Number: XXXX

- XXXX (if applicable)
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 wi th generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem 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 acquirin g and maintaining record storage facilities.

 If cost estimates are expected to vary widel y, 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 p art 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 anal ys is 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 in clude 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 Annuali zed Costs Requested : There are no other costs to the respondents associated with this informati on collection. Grantees are required b y program regulations to collect and maintain this information. The costs to transmit the data electronicall y 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.8

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 directl y b y 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 an y 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 materiall y 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 t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion) , ty

pe of collection (new, revision, extension, reinstatement with ch ange, reinstatement without change) and include totals for changes in burden hours , responses and cost s (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 pa st grant cy cle. The decrease in the number of projects funded is a result of grantees not reappl yi ng 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 co ntinuation award for not making annual substantial progress as required b y the program statute and regulations. Therefore, the number of projects currentl y 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 analy

tical techniques that will be used. Provide the time9

EDICS Tracking and OMB Number: (XXXX) XXXX

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- XXXX (if applicable) schedule for the entire project, including beginning and ending dates of the collection of information, comple tion of report, publication dates, and other actions. Collected information will be anal yz ed annuall y 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 convey ed 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 expirat ion 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 except ion 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 y ears as part of the Postsecondary

Attainment objective. TS projects may either track all postsecondary enrollees or a random sample of th em, 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.