1 Adult Ed. State Plan Guidance Extension of OMB Approval # 1830

- 0026 through 7/31/2017

**SUPPORTING STA**

**TEMENT FOR PA**  **PERWORK REDUCTION A CT 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 colle**  **ction of information.** The Adult Education and Family L iteracy 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 22 4 of PL105

- 220 required States submit to the Department of Education (ED), their plan for address ing 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 continue d 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 successfull y 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 automaticall y grants states a one - year extension due to the expired status of PL 105

- 220. To receive funds under the Adult Education and Family L iteracy 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 FY 15 budget proposal requests appropriations for this program and 2) it appears unlikel y 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 ye ar . Therefore the Department is requesting a 3

- year extension of approval of this information collection , in order to allow States to submit p ertinent 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 mad e of the**  **information received from the current collection.** Section 211(b)(1) of Adult Education and Famil y 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 e ach 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 respons es, and the basis for the decision of adopting this means**  **of collection. A lso 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 du**  **plication. 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. A s such, the Department is only r equesting 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 entitie**  **s (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 b eyond. W ithout this information, we also have no way to measure continuous improvement in the states’ performance on adult education for the coming ye ars. A s a consequence of this, States will not be eligible for incentive grants as outlined in Section 5 03 of PL105

- 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 writt en 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, gov** **ernment 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 dat a classification that has not been**  **review ed 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 con sistent 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 t h**  **a t 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 keepin g, disclosure, or reporting format (if any), and on**  **the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from w**  **hom information is to be obtained or those who must compile records should occur at least once e**  **very 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.** 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 bi

monthly conference calls with the se directors. The meetings and conference calls mentioned above c ontinue to the present.

**9. Explain any** 

**decision to provide any pay**  **ment or gift to respondents, other than remuneration of contractors or grantees.**  Not applica

ble.

**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** 

**conside rs 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 t**  **he 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 w hich 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 w**  **idely 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 t han one form, provide separate**  **hour burden estimates for each form and aggregate the hour burdens in item 1**  **6 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 pay**  **ing 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**  20 15

- 2016 5 7 Professional Clerical TOTAL 40

5 45 2,280

28 5 2 ,56 5 20 16

- 2017 5 7 Professional Clerical TOTAL 40

5 45 2,28 0

28 5 2, 56 5 20 17

- 2018 5 7 Professional Clerical TOTAL 40

5 45 2,28 0

28 5 2,56 5 **TOTAL ANNUAL**  **AVERAGE 2,56**  **5**6

The request for approval is for one form

. The total estimated annual cost to resp ondents is approximately $59,8 50 based upon an average hourly rate of $25 per prof

essional and $10 per clerical. Based on the average preparation time of 45 hours per response, it is estimated that 4 5 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 tw o components: (a) a total capital**  **and start -**  **up co st 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 in formation. Include**  **descriptions of methods used to estimate major cost factors including sy** **stem and technology acquisition, expected useful life of capital**  **equipment, the discount rate(s), and the time period over w hich costs will**  **be incurred. Capital an d start**  **- up costs include, among other items,**  **preparations for collecting information such as purchasing computers and softw**  **are; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining**  **record storage facilities.**

 **If cost estimate s are expected to vary w**  **idely , 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 e stimates, 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 analy sis associated with the rulemaking containing the**  **information coll ection, 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 collec**  **tion, (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 A nnualized Capital/Startup Cost**  **: Total A**  **nnual Costs (O&M) :** 7 **____________________**

**Total A nnualized 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 start
up 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. A**  **lso, provide a description of the method used to estimate cost, w**  **hich 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. A** **gencies also may aggregate**  **cost estimates from Items 12, 13, and 14 in a single table.** Federal costs are e stim ated 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 E STIMATED 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 w**  **hose results will be published, outline plans for tabulation a**  **nd publication. A ddress any**  **complex analy tical 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 actio ns.**  There are no plans for complex analy tical 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 A** **ct**
**.** This request is in compliance with 5 CFR 1320.9