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Annual Performance Report for Grants under the 

Educational Opportunity Centers Program

Supporting Statement for Request for Approval under the Paperwork Reduction Act 

and 5 CFR 1320

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.

The Department of Education (Department) is requesting approval of a new Educational 

Opportunity Centers Annual Performance Report (APR) form to collect annual 

performance report data from projects funded by Educational Opportunity Centers 

(EOC) program grants. This APR reflects new EOC program regulations enacted on 

October26, 2010. The new regulations were necessitated by changes to the EOC

program in the Higher Education Opportunity Act (HEOA) of 2008. FY 2011-2012 is the 

first year of a five year grant cycle during which EOC projects are required to adhere to 

the new regulations.

The EOC program is one of the Federal TRIO Programs (TRIO) that 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; (d)

combinations of such institutions, agencies and organizations. The specific goals of the 

EOC program are to assist adults from disadvantaged backgrounds (e.g., low-income, 

potential first-generation college students) complete secondary education and enroll in 

programs of postsecondary education; and to publicize the availability of financial and 

academic assistance and assist persons who seek to pursue postsecondary education in 

applying for admission and student financial aid (20 U.S.C. 1070a–11 and 1070a–16).

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 

projects’ accomplishments, to make decisions regarding whether funding should be 

continued, and to award "prior experience" (PE) points. The regulations for this 

program provide for awarding up to 15 points for prior experience (34 CR 644.22). 

During a competition for new grant awards, the PE 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 PE points, based on data submitted in the APR, is 

a crucial part of the overall application process.
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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 EOC grantees under the authority of Title IV, 

Part A, Subpart 2, Division 1, Sections 402A and 402F of the Higher Education Act of 

1965, as amended, the program regulations in 34 CFR 644, and the Education 

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

75.732. Attached is a copy of the authorizing statute, as amended in 2008 as the Higher 

Education Opportunity Act, which is the basis for the current program regulations, also 

attached. 

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 PE 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 644.3]). 

In addition, the Department uses the APRs to produce 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 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 EOC projects have been submitting the annual 

performance report via the Internet since 1998.

The data collected are in the 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 

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

program outcomes. The data collected in the APRsare fundamental to this program.

5. If the collection of information impacts small businesses or other small entities, describe any 

methods used to minimize burden.

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 PE points to grantees. 

Without this data collection, the Department would not have the data to assess the PE 

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;

 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.
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This information collection is conducted in a manner consistent with 5 CFR 1320.5(d)(2).

As applicable, the Department has published the 60 day Federal Register notice as required by 5 

CFR 1320.8(d), solicited comments on the information collection prior to submission to OMB. 

Twenty-four respondent’s submitted approximately 66 individual comments (i.e., multiple 

comments from respondents) were received after the 60-day comment period. The 

Department compiled a summary and analysis of the comments as well as information on 

changes to the proposed EOC APR in response to these comments. 

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 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 payment or gift to respondents, other than remuneration 

of contractors or grantees.

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.

No assurances of confidentiality are provided to the respondents.

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.
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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 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. 

 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 1,024. We estimate approximately 

128 respondents. The performance reports are submitted annually.

Number of 

Respondents

Estimated 

Preparation Time, 

per respondent

Total estimated 

burden hours

Public Sector 96 8 hours 768 hours

Private Sector 32 8 hours 256 hours

Total estimated 

burden hours 128 8 hours 1,024 hours

(Estimated burden: 1,024 hrs. Total number of hours (preparation time) multiplied by the total 

number of respondents equals estimated burden hours). Preparation time includes 6 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

(128 respondents X 6 hours X $35 per hour) $26,880
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Clerical staff

(128 clerical staff members X 2 hours X $18 per hour) $4,608

Total estimated cost to all respondents $31,488

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.

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.

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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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 form

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.

In previous years, the same APR form was used for two of the TRIO programs (Talent

Search and EOC) because of the similarities in the data collected for each program. 

However, statutory changes and subsequent new regulations resulted in significant 

differences in the performance measures for these two programs. Therefore, this form 

will only be used to collect data on the EOC participants. Additionally, the final 

regulatory amendments to recordkeeping requirements require that an EOC grantee 

document the services a student, who is served by more than one TRIO or other 

federally funded program, is receiving from another program during the project year. 

This change will not result in an increase in burden hours.

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.

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

its approved goals and objectives and to award PE points. Performance measures and 

efficiency measures for the two programs, 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 2007–08 performance period, at the grantee level; this more 
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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

This collection does not employ statistical methods.