**Veterans Upward Bound Program**  **Request for Approval under the Paperwork Reduction Act Supporting Statement for the New Annual Performance Report Form** 
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 URLlink or paste the applicable section 1 . Specify the review ty

pe 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 o r changed sections, if applicable. The Department of Education ( Department) is requesting approval of a new Veterans Upward Bound ( VUB) Annual Performance Report (APR) form to collect APR report data from projects funded by VU B P rogram grants . This APR reflects new VUB P rogram regulations enacted on Oct ober 26, 2010. The new regulations were necessitated b y changes to the V UB P rogram in the Higher Education Opportunity

Act (HEOA) of 2008. FY 2012

- 2013 is the first y ear of a five year grant cycle during which VUB projects ar e required to adhere to the new regulations. The VUB program is a type of Upward Bound Program that provide s Federal financial assistance in the form of discretionary grants to : (a) institutions of higher education ; (b) public and pri vate agencies and organizations including community

- based organizations with experience in serving disadvantaged persons ; (c) secondary

schools; and (d) combinations of such institutions, agencies and organizations

. The specific g oal of VUB is to provide fundamental support and motivation to veteran participants in their preparation for college entrance and to assist them in the development of academic skills necessary for success in a program of postsecondary education. The program provides intense basic skills development in those academic subjects required for successful completion of high school equivalency opportunities for participants to succeed in their pre

- college performance and ultimately in their h igher education pursuits. VUB provides short

- t erm remedial or refresher courses for veterans who are high school graduates but who have delay ed pursuing postsecondary education. The program also provide s special services, including mathematics and science preparation, to enable veterans to make the transition to postsecondary education. Funded projects are expected to assist veterans in securing support services from other locall y available resources such as the Veterans Administration, State

1 Please limit pasted text to no longer than 3 paragraphs.2 v eterans agencies, veteran associations and other State an d local agencies that serve veterans. The goal of VUB is to increase the rate at which participants enroll in and graduate from institutions of postsecondary education (20 U.S.C. 1070a

- 13). 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 projects’ approved objectives to determine the project s’ accomplishments, to make decisions regarding whether fund ing should be continued, and to award "prior experience" (PE) points. The regulations for this program provide for awarding up to 15 points for PE (34 CR 64 5.3 2). During a competition for new grant awards, the PE points are added to the average of the fi eld 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 PE points, based on data submitted in the APR , is a cruci al part of the overall application process. Further, this performance report form collects aggregate d , quantifiable data needed to respond to the requirements of the Government Performance and Results Act (GPRA) . In the Department ’ s Fiscal Year 2010 Annu al Performance Plan, the overall objective for the V UB Program is to : “Increase the percentage of low

- income, first generation veteran participants who enter and succeed in a program of postsecondary education.” The Department collects information from VU B grantees under the authority of Title IV, Part A, Subpart 2, Chapter 1, Section 402 C of the Higher Education Act of 1965, as amended, the program regulations in 34 CFR 64 5 , and 34 CFR Sections 74.51, 75.720 and 75. 732 of the Education Department General Adm inistrative Regulations (EDGAR)

. URL links: HEOA: http://www2.ed.gov/about/offices/list/ope/trio/statute

- trio

- gu.pdf EDGAR: http://www2.ed.gov/policy /fund/reg/edgarReg/edgar.html Program Regulations: http://www.e cfr.gov/cgi

- bin/text

idx?c=ecfr&sid=b9bc048d99b7bb797a74566d37d8f9ef&rgn=div5&view=text&n ode=34:3.1.3.1.18&idno=34 2. In dicate how, by

whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the ag ency 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 PE points to be awarded to current grantees ; and (c) aid in compliance mon itoring ( i.e ., to determine whether grantees are in compliance with the selection requirements for project participants ) [34. CFR 645.3]

.3 In addition, the Department uses the APRs to produce program

- level data for annual reporting, budget submissions to O ffice of Management and Budget (O MB ) and to Congress , Congressional hearings and testimonials; Congressional 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 adop ting 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 s ystems 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 entir e report via the Internet. The V UB project s have been submitting the APR via the Internet since 2001

. The data collected are in the aggregate form at the program level . Data is not provided for individual participants . Thus , the reports are a low

- level security risk. Nonetheless, the Web site is secured to ensure that the data are seen only b y authorized individuals and are protected from network hac kers. 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 already available cannot be used or modified for use fo r the purposes described in Item 2 above. T he information grantees submit in their performance reports is unique to each project and is not collected elsewhere ; therefore , no duplication exists. N o other collection instrument is available to collect the information the Department is required to assess to determine grantees’ PE points and program outcomes, as described in item 2, above. The data collected in the APR are fundamental to th is program. 5. If the collection of information impacts small busine sses or other small entities, describe an y 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 organi zation 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 wi th a population of less than 50,000. This information collection does not affect small businesses or other small entities.4

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequ entl y, as well as an y technical or legal obstacles to reducing burden. The collection of APRs 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 satisfac tory

progress in meeting the goals and objectives proposed in its initial grant application

. In addition, the information is needed to award PE points to grantees. Without this data collection, the Department would not have the data to assess the PE prov ision 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 co nducted 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 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 ye ars;
 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 n ot 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 confidentia l 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. With on e exception, no information will be collected in the manner covered under an y of the special circumstances outlined. The exception is that respondents are required to retain participant records for more than three ye ars as required under 34 CFR 74.53(b). In order to assess the impact of the program services on participating students’ academic progress , and in anticipation of the new outcome measure s for VUB which occurred as a5

result of the HEOA , grantees should track the academic progress of all prior

- year participants beginning with participants who completed their education program of study in 2008 , until postsecondary completion. 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 clarit y of instruction and record keeping, disclosure, or reporting format (i f 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 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. Five respondents have submitted approximately

eight individual comments (i.e., multiple comments from re spondents) that were received after the 60

- day comment period. The Department compiled a summary

and anal ys is of the comments as well as information on changes to the proposed VUB APR in response to these comments. There is no burden/response/respondent increase from the 60

- day notice public comments. A separate 30

- day Federal Register notice will be published to solicit public comment on the new APR form following the 60

- day Federal Register notice.
9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees. The Department wi ll 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, r egulation, or agency policy . I f personall y identifiable information (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 Impact Assessment was completed as indicated on the IC Data Form. A confidentiality

statement with a legal citation that authorizes the pledge of confidentiality6

should be provided. 2 If the collection is subject to the Privacy Act, the Privacy Act statement is deemed suffic ient with respect to confidentiality

. If there is no expectation of confidentialit y, simply state that the Department makes no pledge about the confidentially

of the data. No assurances of confidentiality are provided to the respondents

. 11. Provide ad ditional 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 why the agency

considers the ques tions 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 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 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 response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden ty pe: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special surv ey s 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 widel y 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, provid e separate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Anal ys is Table. (The table should at minimum include Respondent

2 Requests for th is 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 o f Personally Identifiable Information)7 ty pes, IC activity , Respondent and Responses, Hours/Response, and Total Hours)

 Provide e stimates 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 b e included here. Instead, this cost should be included in Item 14. Estimated burden hours for this collection of information are 867 hours. We estimate approximately 51 respondents

. The performance reports are submitted annually

. Number of Respondent s Estimated

Preparation Time , per respondent Total estimated

burden hours Public Sector 44 17 748 Private Sector 7 17 119 Total s 51 17 867 ( Estimated burden: 867 hours. Total number of hours (preparation time) multiplied by the total number of res pondents equals estimated burden hours). Preparation time includes 1 5 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 ( 51 re spondents X 15 hours X $35 per hour) $ 26,775 Clerical staff ( 51 clerical staff members X 2 h ours X $18 p er hour) $ 1,836 Total estimated cost to all respondents $ 28,611
Note : As man y of the respondents are project staff whose salaries are lar gely 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. 13. Provide an estimate of the total annual cost burden to resp ondents 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 (annuali zed over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates8 should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include d escriptions 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 incl ude, 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 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 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 anal ys is associated with the rulemaking containing the information collection, as appropriat e.

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

. Grantees are required b y p rogram 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 an y other expense that would not have been incurred without this collection of in formation. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. 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. Annual contract cost for development of APR Web application, Web

- based data collection, Help Desk support, data processing, and grantee PE reports. $ 36,689 Analy ses of data and preparation of national statistical reports. $ 35,0009 Professional staff to update report form and prepare clearance package: $55 per hour X 120 hours Overhead (est. at 50%): 120 times $27.50 $9,900 Professional staff to review and edit reports for dissemination : $55 per hour X 160 hours Overhead (est. at 50%): 160 times $27.50 $13,200 Clerical staff to t ype, route, and cop y report form: $ 19 per hour X 15 hours Overhead costs (est.at 50%) : 15 times $ 9.5 0 $42 8 Other Department staff to review and approve the request: $55 per hour X 10 hours Overhead costs (est. at 50%) : 10 times $ 27.50 $825 OMB review (estimated): $55 per hour X 8 hours O verhead costs (est. at 50%) : 8 times $ 27.50 $660
TOTAL FEDERAL COST $ 96,70 2 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 generall y 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 b y ty pe of change (i.e., adjustment, program change due to new statute, and/or program change du e to agency discretion), ty pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours, responses and costs (if applicable). In previous ye ars, the same APR was used f or three of the TRIO programs (Upward Bound, Upward Bound Math and Science and Veterans Upward Bound) because of the similarities in the data collected for each program. However, s tatutory changes and subsequent new regulations resulted in significant di f ferences in the performance measures for the VUB p rogram. Specifically , grantees must track the academic progress of VUB participants through postsecondary

completion and this will increase the reporting burden by six hours for each grantee. Therefore, this form will be used to collect data on VUB participants . Additionally , the final regulatory amendments to recordkeep ing requirements require that a VUB grantee document the services a student who is served b y more than one TRI O or other federally funded program is receiving10 from ano ther program during the project ye ar. This change will result in an increase of two additional burden hours

. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address an y complex anal yt ical 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. Collected i nformation will be anal yz ed annuall y to determine if each grantee is meeting its approved goals and objectives and to award PE points. Performance measures and efficiency

measures for VUB , based on data conveyed in grantees' APRs , 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 200 7

– 0 8 performance period, at the grantee level ; this more detailed reporting has been made poss ible due to improvements in accuracy result ing 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 wo uld 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 A ct. There are no exceptions to the certification statement. B. Collections of Information Employing Statistical Methods This collection does not employ statistical methods.