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Annual Performance Report for Grants under the

Ronald E. McNair Postbaccalaureate Achievement Program

Supporting Statement for Request for Approval under the 

Paperwork Reduction Act and 5 CFR 1320

Supporting Statement

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 Department of Education (Department) is requesting approval for a revised collection of a 

currently approved collection. The Ronald E. McNair Postbaccalaureate Achievement (McNair) 

Program Annual Performance Report (APR) will expire on January 31, 2014 (OMB No. 1840-

0640). 

Through a grant competition, McNair Program funds are awarded to institutions of higher 

education to prepare eligible participants for doctoral studies through involvement in research and 

other scholarly activities. Participants are from disadvantaged backgrounds and have demonstrated 

strong academic potential. Institutions work closely with participants as they complete their 

undergraduate requirements. Institutions encourage participants to enroll in graduate programs and 

then track their progress through to the successful completion of advanced degrees. The goal is to 

increase the attainment of Ph.D. degrees by students from underrepresented segments of society.

The obligation to respond to this collection is required to obtain or retain benefit under Title IV, 

Section 402E, of the Higher Education Act of 1965, as amended (Public Law 102-325), 

the program regulations in 34 CFR Part 647; and sections 75.590, and 75.720 of the 

Education Department General Administrative Regulations (EDGAR) permit the 

collection of this information. 

The information submitted in the annual performance report is used to meet several regulatory and 

statutory requirements. 

Prior Experience (PE) Points

First of all, the data collected via the McNair APR is used to assign prior experience points as 

mandated by the McNair Program authorizing statute, Title IV, Part A, Subpart 2, Chapter 1, 

Section 402A(f)(3)(D) of the Higher Education Act of 1965, as amended, which states:

“For programs authorized under section 403E, the extent to which the entity met or exceeded the 

entity’s objectives for such programs regarding—

(i) the delivery of service to a total number of students served by the program, as agreed upon 

by the entity and the Secretary for the period;

(ii) the provision of appropriate scholarly and research activities for the students served by the 

program;
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(iii) the acceptance and enrollment of such students in graduate programs; and

(iv) the continued enrollment of such students in graduate study and the attainment of doctoral 

degrees by former program participants.”

The calculation of prior experience points is done on an annual basis using the data the project 

submits for the reporting period. As such, during a competition for new awards, the prior 

experience points are added to the average of the field readers’ scores to derive a total score for 

an application. A slate of all applicants is developed on the basis of the total scores of the 

applications. Funding recommendations and decisions are based on the rank order of applicants 

on the slate. Therefore, the assessment of prior experience points is a crucial part of the overall 

application process.

Evaluation of Substantial Progress

Secondly, during non-competitive years, the reports are used to verify that grantees are making 

substantial progress toward the achievement of approved objectives prior to issuing continuation 

awards.

Government Performance and Results Act (GPRA)

Thirdly, the Department is committed to continually improving its management of programs and 

improving the educational outcomes of students. Improvements are guided by monitoring and 

assessing performance, improving the data used for these assessments, collaborating with 

stakeholders, implementing recommendations, and re-assessing performance. Providing data to 

the public is a key element in promoting improvement and collaborating with stakeholders. 

Therefore, to meet these goals the APR collects aggregate and quantifiable data needed to 

respond to the requirements of the Government Performance and Results Act (GPRA). The 

performance outcomes that are measured are:

—the acceptance and enrollment of project participants in graduate study, and

—the continued enrollment of project participants in graduate study.

HEOA Reports to Congress

Finally, Section 402H(a) mandates the Secretary to submit annually, to Congress a report that 

documents the performance of all programs funded under Chapter 1 and shall focus on the 

programs’ performance on the relevant outcome criteria determined under section 402A9f)(4). 

Therefore, the data contained in the McNair APR is used in order to carry out the provisions of 

the statute. Specifically, the Department aggregates the data provided in the individual APRs and 

makes this data available on the TRIO website and in the congressional justifications.

The McNair Program is authorized by Title IV, Part A, Subpart 2, Section 402E of the Higher 

Education Act of 1965, as amended (P.L.102-325); the program regulations in 34 CFR Part 647; 

and the Education Department General Administrative Regulations (EDGAR), Parts 74, 75, and 

77, 79, 82, 85, and 86. The authorizing statute is included in the attached application booklet. 

The respondents under the collection are institutions of higher education or combinations of those 

institutions.

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.

As mentioned in above, the Department uses the data collected to: (a) determine the number of 

prior experience points to be awarded for the purpose of awarding the grant, (b) evaluate

substantial progress to aid in compliance and monitoring as well as funding, (c) respond to the 
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requirements of the Government Performance and Results Act (GPRA), and (d) respond to the 

statutory requirement regarding reports to Congress on program outcomes.

In addition, the annual performance reports are used to collect programmatic data for purposes of 

annual reporting; budget submissions to OMB; Congressional hearing 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 

adopting this means of collection. Also describe any consideration given to using technology to 

reduce burden.

The data being requested 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 McNair projects 

have been submitting the annual performance report via the Internet for the past five years. For 

project year 2011-12, 99% of the current grantees submitted via the Internet. 

The data collected is summary information on project participants and services and poses a lowlevel security risk. Nevertheless, the web site is secured to ensure the data are only seen by 

authorized individuals and are protected from network hackers.

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 submitted in the report is unique to each respondent, no duplication exists. 

There is no other collection instrument that is available to collect the information that is being 

requested. The data collected in the APR are fundamental to the McNair program.

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.

This information collection does not involve 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 application, prior to 

awarding continuation funding. In addition, the information is needed to award prior experience 

points to grantees. Without this data collection, the Federal TRIO Programs will be unable to 

award non-competing continuation awards, use the data to assess the prior experience provision of 

the authorizing statute, respond to the GPRA reporting requirements and efficiency measures 

requirements, respond to the statutory requirement regarding the reporting of outcomes data to 

Congress, and 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;
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 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-inaid, 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.

With one exception, no information will be collected in the manner covered under any of the 

special circumstances outlined. The exception is that respondents are required to retain 

participant records for a period of ten years. In order to assess the impact of the program 

services on participating students’ academic progress, grantees are required to track the 

academic progress of all prior-year participants until they attain a doctoral degree, or until they 

are inactive in the pursuit of their academic objective for five years.

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.

A separate 60-day Federal Register notice followed by a 30-day Federal Register notice will be

published to solicit public comment on the new APR form. 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.
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9. Explain any decision to provide any payment or gift to respondents, other than remuneration of 

contractors or grantees.

The Department does not provide any payments 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.

The Department's disclosure policies adhere to the provisions of the Privacy Act – PL 95-379, 5 

USC 552a. There is no assurance of confidentiality with respect to grant-required reports; 

however, grantees are instructed to insure that program participants are informed of their rights 

under the Privacy Act with respect to the disclosure of social security numbers. A disclosure 

statement is provided to students at intake or involving other activities that occur during their 

time with the McNair project.

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 annual performance report form does not include questions about sexual behavior and 

attitudes, religious beliefs or other items 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 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 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.

The estimated burden hour for this collection is 11 hours. We estimate approximately 158

respondents x 1 report each. 

Estimated Burden Hours

Estimate

Public 

Sector

Private, Non-profit, 

Sector Total

Estimated number of 

respondents 115 43 158
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Estimated preparation time 11 11 11 hours

Total estimated burden 

hours 1,265 473 1,738

Estimated Burden: 11 hours Total—Number of hours [preparation time] divided 

by the total number of respondents equals estimated burden hours.) 

The burden hours allotted for recordkeeping and reporting burden includes activities related to the update 

and review of data, responses to inconsistencies in the data reported, and data entry into the web portal.

Most of the costs of this data collection are those of the Federal Government, since the respondents are 

project staff paid for the most part with Federal grant funds. Nonetheless, the annual cost to the grantee 

to respond to this data collection is estimated as follows:

Estimated annual costs to respondents

Professional (158 personnel X 10 hours @ $35 per hour) $55,300

Clerical (158 clerical X 1 hour @ $16 per hour) $2,528

Total estimated costs to respondents $57,828

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.

Total Annualized Capital/Startup Cost: ______________________

Total Annual Costs (O&M): _______________________________

Total Annualized Costs Requested:__________________________

There are no other costs to the respondents. 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.
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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.

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 in collecting, aggregating and 

disseminating the information.

Estimated annual cost to the Federal Government

Federal Professional Staff Cost Cost

Professional staff to develop clearance package

(GS-14 employee) 45 hrs. @ $55.00 per hour $2,475.00

Overhead cost related to facilities, administration, and other indirect cost plus 

accrual of leave and fringe benefits @ 50% of salary of $2,475 $1,238.00

Other Department staff to review and approve the request:

(GS 15 employee) $65 per hour X 14 hours = $910.00

(GS 14 employee) $55 per hour X 20 hours = $1,100.00

Overhead costs: $2,010.00 X 50 percent = $1,005.00 $3,015.00

OMB Review (estimated)

12hrs x $47.00 per hour 

Overhead costs: $564 X 50 percent

$564.00

$282.00

Other Administrative Costs

Annual Web Development—Annual contract cost for development of APR 

Web application, Web-based data collection, Help Desk support, data 

processing, and grantee PE reports $108,570.22

Annual Data Analysis—Analyses of data and preparation of national summary 

and individual project reports (contractor costs) $140,000.00

Total Annual Government Cost $256,144.22

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

The regulatory amendments to the PE criteria, which address statutory requirements for long-term 

tracking of the academic progress of McNair participants through completion of the doctoral 

degree, will increase the reporting burden by four hours for each grantee. In addition, the final 

regulatory amendments to recordkeeping requirements will require that a McNair 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 is a new data collection requirement 

that also will increase a grantee's burden by an estimated two hours. Therefore, the total number of 

burden hour per respondent increase is six (6) hours. In addition, the McNair Program was recompeted in FY2012 which resulted in a net decrease of 42 respondents due to the budget 

allocation. For detailed information regarding the revisions to the McNair APR, please see 

Appendix A at the end of this document.

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.

Results of the collected information will not be published.
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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.

The Department will display on the form the expiration date for the OMB approval as required.

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. Collection of Information Employing Statistical Methods statement.

The collection of information does not employ statistical methods.
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Appendix A—Revisions to the McNair APR

1. Redesign 

The McNair APR fields was redesigned so that where possible, fields pertaining to similar topics and fields 

that reference each other were placed within the same section in the APR. As such, the McNair APR contains 

the following sections:

 Section I, Part 1—Project Identification/Characteristics Certification and Warning Statements

 Section I, Part 2—Project Services

 II.A. Project Identifiers (pre-populated)

 II.B. Participant’s Personal Information 

 II.C. Participant’s Demographic Information and Eligibility Status

 II.D. Participant’s Project Enrollment Information

 II.E. Participant’s Academic and Degree Status

 II.F. Participant’s Research and Internships during the Academic Year

 II.G. Participant’s Graduate School Information

2. New Data Fields

In order to comply with the statutory requirements regarding the Prior Experience (PE) points, the 

congressionally mandated reports to Congress on student outcomes, program administration and 

monitoring, and GPRA requirements, it is necessary to add several new fields. These fields will allow the 

Department to calculate PE for the competitions and provide information on student outcomes. The new

fields that were added are:

Field # Field Name Citation Purpose

Section I, 

Part 1, 9d

Implementation of STEM 

Program

34 CFR 75.105(c)(2)(i) The Department views the McNair Program as a critical 

component in the effort to improve the quality of student 

outcomes so that more students are well prepared for college 

and careers. To more strategically align the McNair 

Program with overarching reform strategies for 

postsecondary completion and graduate school enrollment, 

the Department is announcing three competitive preference 

priorities for this competition.

Section I, 

Part 1, 9e

Development of Evidence 

Based System to Evaluate 

Performance

34 CFR 75.105(c)(2)(i) The Department views the McNair Program as a critical 

component in the effort to improve the quality of student 

outcomes so that more students are well prepared for college 

and careers. To more strategically align the McNair 

Program with overarching reform strategies for 

postsecondary completion and graduate school enrollment, 

the Department is announcing three competitive preference 

priorities for this competition.

Section I, 

Part 2

Required and Permissible 

Services

Section 402E(b)(2) of 

HEOA

Program requirement and administration

15 Hours worked Per Week Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program

outcomes

Important for understanding other time demands that may 

impact time to degree completion as it relates to student 

outcomes.
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Field # Field Name Citation Purpose

26 Main Field of 

Undergraduate Study

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program

outcomes

Assess different outcomes by undergraduate field of study 

as research shows variation between STEM and non-STEM 

fields.

28 Attendance at Community 

College

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program

outcomes

Assess student outcomes based on attendance at community 

college 

29 Bachelor’s or Equivalent 

Degree

Section 402A(f)(3)(D) of 

HEOA—Calculation of 

Prior Experience (PE) 

Points

Determine whether or not bachelor’s degree has been 

attained and will be used in conjunction with field #31.

30 Date of Bachelor’s or 

Equivalent Degree

Section 402A(f)(3)(D) of 

HEOA—Calculation of 

Prior Experience (PE) 

Points

Determine whether or not bachelor’s degree has been 

attained and will be used in conjunction with field #31.

31 Academic (Cohort) Year 

of Bachelor’s Degree

Section 402A(f)(3)(D) of 

HEOA—Calculation of 

Prior Experience (PE) 

Points

Establish the bachelor’s degree cohort for the doctorate 

degree attainment objective. This field is the denominator 

for the doctorate degree objective.

34 Graduate School 

Admissions Test

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program

outcomes

Use in sampling to conduct a more precise comparative 

analysis using other data sources such as B&B.

35 Number of Graduate 

School Applications

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program 

outcomes.

Use in sampling to conduct a more precise comparative 

analysis. This field aligns with B&B and will be used to 

conduct a comparative analysis for the congressionally 

mandated reports to Congress.

37 Date of First Graduate 

School Enrollment

Section 402A(f)(3)(D) of 

HEOA—Calculation of 

Prior Experience (PE) 

Points and Section 402H 

of HEOA—Congressionally 

mandated report to 

Congress for assessing 

program outcomes.

Used to calculate PE and in calculating graduate school 

enrollment student outcomes for GPRA.

38 Institution Attended for 

First Year Graduate 

Students

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program 

outcomes.

Allows for comparison of graduate school outcomes by 

characteristics of the graduate institution.

40 Graduate Assistantships Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program 

outcomes.

Used as an important element I understanding graduate 

persistence. This field aligns with B&B and will be used to 

conduct a comparative analysis for the congressionally 

mandated reports to Congress.

41 First-Year Graduate 

Student Persistence Status 

Section 402A(f)(3)(D) of 

HEOA—Calculation of 

Prior Experience (PE) 

Points

Used to calculate PE and in calculating graduate school 

persistence student outcomes for GPRA.
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3. Data Fields that have been deleted or relocated 

The following fields are no longer needed either because they are no longer applicable to the program or 

are duplicative and as such have been deleted from the proposed McNair APR.

Field # Field Name Citation Purpose

45 Institution Where Ph.D. 

was Earned

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program 

outcomes.

Allows for comparison of doctorate degree outcomes by 

characteristics of the graduate institution.

46 Doctorate Student’s 

Employment Activity

Section 402H of HEOA—

Congressionally mandated 

report to Congress for 

assessing program 

outcomes.

Allows for comparison of doctorate degree program goal—

PhD in a teaching or research field.

Field # Field Name Reason for Deletion/Relocated

3 Record Update New reporting requirement no longer necessitate the need for this field; therefore, this field 

has been deleted.

18 College Grade Level (At 

the end of the 

spring/summer term)

The McNair program serves mostly juniors and seniors (86%); therefore, this field is 

duplicative and as such has been deleted.

24 GPA Scale The purpose of Section I is to collect information at grantee-level. The purpose of Section 

II is to collect information at the student-level. Therefore, since GPA scale is a 

characteristic of the grantee and not the student, the field has been relocated to Section I.

28 - 34 Seminars, Tutoring, 

Academic Counseling, 

Financial aid, Admission 

Assistant to Graduate 

School, Mentoring, 

Exposure to cultural 

events, financial literacy

These fields do not need to be collected at the student-level since the information is more 

relevant to project/program administration than student level outcomes; therefore, these 

fields have been relocated to Section I.

43 Tacking Completed New reporting requirement no longer necessitate the need for this field; therefore, this field 

has been deleted.

44 Special Circumstances Student outcomes for the purpose of PE are now standardized; therefore, this field is no 

longer applicable and as such has been deleted.