1

Adult Ed. State Plan Guidance

Extension of OMB Approval # 1830-0026 through 7/31/2017

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. 

Attach a copy of the appropriate section of each statute and regulation mandating 

or authorizing the collection of information.

The Adult Education and Family Literacy Act (AEFLA), Title II of the Workforce 

Investment Act of 1998 (WIA), Public Law 105-220 provides formula funding to States to 

support adult education instruction at the State level. Section 224 of PL 105-220 required 

States submit to the Department of Education (ED), their plan for addressing the 

requirements of the Act, including agreeing upon levels of performance identified in section 

212. Congress did not enact new legislation prior to the expiration of the law in 2003;

however, it continued to extend program appropriations for each additional year in each 

subsequent annual appropriation law.

When the law expired at the end of FY 2003, the Department successfully sought OMB 

clearance for the State Plan Guide under AEFLA designed to advise States on how to 

continue their adult education program. This is permissible under Section 422 of the General 

Education Provisions Act (GEPA) (20USC 1226 (a)), which automatically grants states a

one-year extension due to the expired status of PL 105-220. To receive funds under the 

Adult Education and Family Literacy Act (AEFLA), states must submit plans that meet the 

requirements of the Act and agree upon annual levels for core indicators of performance.

Two circumstances make the collection of information necessary: 1)the Administration’s 

FY15 budget proposal requests appropriations for this program and 2) it appears unlikely that 

Congress will pass a reauthorization of the WIA prior to the date by which guidance must be 

released to the states for updates pertaining to the next program year. Therefore the 

Department is requesting a 3-year extension of approval of this information collection, in 

order to allow States to submit pertinent information to the Department in future years, as it 

is required for program administration.
2

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.

Section 211(b)(1) of Adult Education and Family Literacy Act (AEFLA) requires that states 

have an approved State plan on file in order to receive their allotments of federal adult education 

funds. The plans govern adult education program operations in each state. Section 224 requires 

that plans contain a description of performance measures cited in Section 212 (b)(2)(a). The 

Department will ask states to: 1) update these performance targets for each year the law is not 

authorized and 2) include details of any new projects on which federal adult education funds are 

to be expended. The information requested contains updates that will be used to extend on file 

State plans for at least one year and will enable the Department to distribute annual federal adult

education allotments in FY 2015 and beyond while WIA reauthorization is pending.

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.

This information will be transmitted electronically as a Word file.

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.

The State Plan Guide emphasizes the revisions requested as “simply updated versions of the 

original plans.” The Department is taking a targeted approach to ensure States not duplicate their 

efforts in submitting information to us. As such, the Department is only requesting information

about States’ new performance levels, whether a local subgrant competition will be undertaken 

or current subgrants simply extended, and a description regarding the new State leadership 

activities they planned to undertake (if any).

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

entities (Item 8b of IC Data Part 2), describe any methods used to minimize 

burden.

No impact.
3

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 information the Department is seeking is a requirement of funding, per Section 211 of PL 

105-220. This information will enable the Department to distribute annual federal adult

education allotments in FY 2015 and beyond. Without this information, we also have no way to 

measure continuous improvement in the states’ performance on adult education for the coming 

years. As a consequence of this, States will not be eligible for incentive grants as outlined in 

Section 503 of PL 105-220.

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;

 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.

There are no special circumstances.
4

8. If applicable, provide a copy and identify the date and page number of 

publication in the Federal Register of the agency’s notice, required by 5 CFR 

1320.8(d), soliciting comments on the information collection prior to 

submission to OMB. Summarize public comments received in response to 

that notice and describe actions taken by the agency in response to these 

comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their 

views on the availability of data, frequency of collection, the clarity of 

instruction and record keeping, disclosure, or reporting format (if any), and on 

the data elements to be recorded, disclosed, or reported.

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.

No public comments have been received today in response to publication in the Federal Register.

We have discussed ongoing state plan update requirements at our annual (spring) meeting of 

state directors of adult education. Ongoing consultation has also been achieved through bimonthly conference calls with these directors. The meetings and conference calls mentioned 

above continue to the present.

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

remuneration of contractors or grantees.

Not applicable.

10. Describe any assurance of confidentiality provided to respondents and the 

basis for the assurance in statute, regulation, or agency policy.

No assurances of confidentiality provided.

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.
5

No such questions.

12. Provide estimates of the hour burden of the collection of information. The 

statement should:

 Indicate the number of respondents, frequency of response, annual hour 

burden, and an explanation of how the burden was estimated. Unless 

directed to do so, agencies should not conduct special surveys to 

obtain information on which to base hour burden estimates. 

Consultation with a sample (fewer than 10) of potential respondents is 

desirable. If the hour burden on respondents is expected to vary widely

because of differences in activity, size, or complexity, show the range of 

estimated hour burden, and explain the reasons for the variance. 

Generally, estimates should not include burden hours for customary

and usual business practices.

 If this request for approval covers more than one form, provide separate 

hour burden estimates for each form and aggregate the hour burdens in 

item 16 of IC Data Part 1.

 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.

Program 

Year

Estimated 

Number of 

Responses

Type of Staff Estimated 

Number of 

Burden 

Hours Per 

Response

Total 

Estimated 

Number of 

Burden 

Hours

2015-2016 57 Professional

Clerical

TOTAL

40

5

45

2,280

285

2,565

2016-2017 57 Professional

Clerical

TOTAL

40

5

45

2,280

285

2,565

2017-2018 57 Professional

Clerical

TOTAL

40

5

45

2,280

285

2,565

TOTAL

ANNUAL 

AVERAGE

2,565
6

The request for approval is for one form.

The total estimated annual cost to respondents is approximately $59,850 based upon an average 

hourly rate of $25 per professional and $10 per clerical. Based on the average preparation time 

of 45 hours per response, it is estimated that 45 hours would be used for review, research, 

gathering information, and compiling information into a report.

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 preOMB submission public comment process and use existing economic or 

regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or 

services, or portions thereof, made: (1) prior to October 1, 1995, (2) to 

achieve regulatory compliance with requirements not associated with the 

information collection, (3) for reasons other than to provide information or 

keep records for the government, or (4) as part of customary and usual 

business or private practices.

Total Annualized Capital/Startup Cost: 

Total Annual Costs (O&M) : 
7

____________________

Total Annualized Costs Requested :

The total for the capital and start-up cost components for this information collection is zero. The 

information collection will not require the purchase of any capital equipment or create any startup costs. Computers and software used to complete this information collection are part of the 

respondents' customary and usual business or private practices, and therefore are not included in 

this estimate.

The total for operation and maintenance and purchase of service components for this information is 

zero. The information collection will not create costs associated with generating, maintaining, and 

disclosing or providing the information not already identified in question 12 of this supporting 

statement.

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.

Federal costs are estimated to be approximately $81,557. This includes salaries and expenses of 

program staff that manage the review process. The method used to estimate the cost is as 

follows:

Program 

Office Staff

Estimated 

Number of 

Hours Per Year

Hourly Rate Estimated Cost 

Per Year

Total Costs 

for Three 

Years

1 GS-9

5 GS-14s

1 GS-15

145 

358.5 * 4

75 * 1

25

$26.39

$50.41

$52.09

$61.28

 $3,827

+$72,291

+ $3,907

+ $1,532

 $81,557

 $11,481

+$216,873

+ $11,721

+ $4,596

 $244,671

TOTAL ESTIMATED ANNUAL FEDERAL COST = $ 81,557

15. Explain the reasons for any program changes or adjustments to #16f of the IC 

Data Part 1 Form.

No changes.
8

16. For collections of information whose results will be published, outline plans 

for tabulation and publication. Address any complex analytical techniques that 

will be used. Provide the time schedule for the entire project, including beginning 

and ending dates of the collection of information, completion of report, 

publication dates, and other actions.

There are no plans for complex analytical techniques or for publication of data from this collection, 

although each State’s plan is a public document.

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.

We are not seeking this approval.

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

Certification of Paperwork Reduction Act.

This request is in compliance with 5 CFR 1320.9