1

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  **SUPPORTING STA**

**TEMENT FOR PA**  **PERWORK REDUCTION A CT SUBMISSION**  **[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **National Reporting System for Adult Education** 

## A.	Just **ificat ion**  **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 URL link or paste the applicable**  **section. Please limit pasted text to no longer than 3 pages. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without**  **change). If revised, briefly specify the cha nges. If a rulemaking is involved, make note of**  **the sections or changed sections, if applicable**
. Title II of the Workforce Investment Act (WIA
-- P.L . 105
- 220), entitled the Adult Education and Family Literacy Act (AEFLA), creates a partnership among the F ederal government, S tates, and localities to provide, on a voluntary basis, adult education and literacy services. 1 Section 212 of Title II requires that a comprehensive performance accountability

system be established to assess the effectiveness of eli gible agencies in achieving continuous improvement of adult education and literacy activities in order to optimize the return on the F ederal investment. Title II of the Workforce Innovation and Opportunity Act (WI OA

– P.L
. 113
- 128 ), was enacted on July 22, 2014 and becomes effective on July 1, 2015
. T he current WIA accountability requirements of the National Reporting System (NRS) will remain in effect until new requirements under WI OA are implemented , which is not scheduled to occur until the program year that begins on July 1, 2016. The accountability

system under WIA must include the following measures of performance
. The se measures are referred to in AEFLA as “core indicators” : 1. demonstrated improvements in adult learners’ literacy skill levels; 2. p lacement in, retention in, or completion of postsecondary education , training , unsubsidized employ

ment or career advancement; and 3. receipt of a secondary school diploma or its recognized equivalent.

1 AEFLA can be found a t the following link: http://www.gpo.gov/fdsys/pkg/PLAW

- 105publ220/html/PLAW

105publ220.htm2

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  States submit 1 0 required tables , 6 optional tables , 4 fi nancial reports, 1 narrative report, and 1 data quality

checklist. These table and report forms are included in the document named “ In strument
. ” States include in the tables all participants in programs: 1. that meet the purposes of AEFLA, and 2. for wh ich expenditures are reported on the Federal Financial Report. Under AEFLA, States must consider the performance of a subrecipient on the measures as one factor in determining the subrecipient ’s eligibility for funding (Section 224 (b)(3) )
. Section 212 (c) req

uires each eligible agency to report annually

to the Secretary

on its progress in achieving its targets , including inform ation on the levels of performance achieved with respect to the core indicators of performance. The Secretary (Section 212 (c)(2) ) is required to make the information contained in the S tate reports available to the public, disseminate State

- by

- State comparisons of the information, and provide the appropriate committees of Congress with such reports. In addition, the Secretary is to cons ider eligible agency

performance on the core indicators of performance in awarding performance incentive grants to S tates (Section 50 3 ). Two other legislative and regulatory statut es require the collection of this information : The Government Performance and Results Act (GPRA) of 1993 and the Education Department General Administrative Regulations (EDGAR). The Government Performance and Results Act (GPRA) of 1993 . The Government Performance and Results Act (GPRA) of 1993 require s each Federal agenc y to develop a strategic plan to ensure that its services are delivered efficiently and in a manner that best suits client needs and to develop indicators of performance to demonstrate the agency ’s impact. The GPRA indicators for the Division of Adult Education and L iteracy within the Office of Career, Technical, and Adult Education (OCTAE) are improvements in student literacy levels (referred to as “educational gain”) and other “follow

- up” outcome measures. O CT AE plans to obtain this information from th is d ata collection extension package
. The Education Department General Administrative Regulations (EDGAR). Inaddition to the accountability requirements contained in AEFLA , EDGAR requires grantees to submi t performance reports not more frequently than quarterly

or less frequently

than annually

(34 CFR 80.40). Those regulations also require grantees to submi t financial status reports not more frequently

than quarterly

or less frequently

than annually

(34 CFR 80.41). In201 4 , OMB most recently approved the data collection required by AEFLA (OMB 1830

- 0027). O CT AE is requesting an exten sion of this approval. As proposed here, this collection contains minor changes from the collection approved in 201 4 . These changes are described below : In2011 , OMB approv ed changes in the way cohorts are defined for purposes of this data collection. Prior to these 2011 changes , states only collected data on a specific outcome measure for adult education participants who set the goal to achieve that outcome. As a3

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  result o f the changes approved in 2011 , states must report outcome data on all participants who meet the criteria for a specific follow

- up measure . The new cohort definition s enlarge d the size of the cohort s for reporting purposes. Italso gave states the optio n of using a representative group of cohort members to determine whether they have met the outcome measure. This option reduce s the data collection burden for those states that elect to use it. In 2014, OCTAE released several new automatic validation fun ctions in its web

- based reporting system used for this data collection
. These new automatic validation functions give s tate s immediate notice of any discrepancy in the data they enter, allowing a s tate to correct the discrepancy

before submitting its data to OCTAE . These database enhancements increase the efficiency of the data collection process , reduce burden, and ensure the quality

of the data that s tates report. The change proposed by

this request is to modify the learning objectives associated with each educational functioning level identified in the NRS . Through a pre

- post assessment process, the learning objectives and educational functioning levels are used to measure whether programs have produced educational gains among participants for perfor mance reporting purposes. The educational gains indicate whether a program is moving participants toward a post

- secondary credential or employ

ment. As proposed here, the modified learning objectives, known as descriptors, will help modernize the accountability system to reflect the adult educational demands of the 21 st Century
. The current NRS educational functioning level descriptors remain in effect until further notice from OCTAE. While the current NRS educational functioning level descriptors will remain in effect until further notice from OCTAE, publication of the modified descriptors at this time will help States align their instructional program to the current demands of post

- secondary education and the modern workplace. **2. Indicate how, by wh om, 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.**  O CTAE uses the information received from the current collection to f ulfill three WIA requirements outlined in Sections 503, 243, 212, and, to ensure our compliance with the Government Performance and Results Act of 1993. **Section 503** WIA authorizes Section 503 incentive awards for States that exceed their performance le vels established in their State plans. The Department of Education ( ED ) will use the information reported to determine whether performance levels have been exceeded and determine each State’s eligibility for these awards. **Section 243**4

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  WIA Section 243 requ ires ED to provide technical assistance to s tates and evaluate the effectiveness of local programs. ED will use the information reported to identify which s tates have not reached acceptable levels of performance and may need technical assistance from ED to improve their service delivery system. The information will also be used to identify

high performing States that can show the performance levels that are possible and how to achieve them
. **Section 212** The Department will use the information received from the current collection to fulfill the reporting requirements in Section 212(c)(2) of WIA and O CT AE’s reporting requirements under GPRA. AEFLA sets reporting requirements for Title II that state that the Secretary of ED shall: 1. publish data on each St ate ’s performance indicators, 2. disseminate State
- by

- State comparisons of performance, and 3. report to the appropriate committees of the U.S. Congress on State performance. Inaddition to the purposes above, O CT AE has used the information from this data co llect ion extension proposal for its monitoring efforts and for budget justification. **GPRA** GPRA require s all Federal agencies to develop strategic plans to ensure that their services are delivered efficiently

and in a manner that best suits client needs and to develop indicators of performance to demonstrate their agency ’s impact. O CT AE ’s approved GPRA indicators for the Division of Adult Education and Literacy are improvements in student literacy

levels (referred to as “educational gain”) and other foll ow - up outcome measures. OCTAE plans to obtain this information on student outcomes from the accountability

system that is the subject of this OMB data collection extension proposal
. **3. Describe whether, and to what extent, the collection of informati on 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 collecti on. Also describe any consideration**  **given to**  **using technology to reduce burden.** Over the past several years, States have developed individual student record systems using relational databases to track students and to meet reporting requirements within th e States. Technology

continues to play

a significant role in the collection of data from the States, significantly

reducing the burden of data collection and analysis. States will prepare the statistical reporting information required by this data coll ection extension proposal through their individual student record systems and submit this information to OCTAE electronically . To assist States in electronic reporting, in 2004, O CT AE created a web

- based database system known as the National Reporting Syst em for5

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  adult education (NRS ) . The NRS facilitates the reporting of statistical and financial data that is required for national program comparability and to ensure overall program accountability . This sy stem automates the process by which States collect , compile , and report the data and results in a paperless annual reporting system. T he electronic compilation and annual submission of th ese data makes the collection more efficient and accurate . Rather than compiling individual paper reports from each lo cal program into one State report, the web

- based submission automatically compiles the data and eliminates any

manual calculations at the State or Federal level. Validation functi ons, alerting state officials to data discrepancies, ensure that the data are of high quality
. Lastly , the web

- based reporting system allows States to submit statistical, financial and narrative reports electronically , in an integrated, seamless fashion. **4. Describe efforts to identify duplication. Show specifically why any s imilar information**  **already available cannot be used or modified for use for**  **the purposes described in Item 2 above.** The information to be collected in the annual reports is not available from any other source and the collection of the information will not duplicate any existing data collection efforts. **5. I**  **f the collection of information impacts small businesses or other small entities, describe any 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 organization 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 jur isdiction, which is a government of a city, county, town, township, school**  **district, or special district with a population of less than 50,000.** No small organizations or small businesses are affected by this data collection. **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.** There would be several important consequences of not collecting this information or collecting it less frequently
. I f the collection did not occur, ED would be unable to comply with several statutory

mandates, including the requirement in S ection 212(c)(2) that OCTAE submit an annual report to Congress on the extent to which States have met their agreed

- upon performance levels,
. The Department would also be in noncompliance with GPRA reporting requirements , if this information could not be collected to develop performance reports. In addition, the annual incentive awards described in S ection 503 are based on these data. Less frequent collections will either make it necessary to grant these awards based on outdated data or will make it impossible to grant the incentive awards on an annual basis, as required by law.6

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education** 

**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 inf ormation 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 recor**  **ds 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 r eviewed 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**  **unn ecessarily 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 th**  **a t it has instituted procedures to**  **protect the information’s confidentiality to the extent permitted by law.**  No special circumstances apply to this effort. **8. As applicable, state that the Department has published the 60 and 30 Federal Register**  **notices as required by 5 CFR 1320.8(d), sol iciting 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 cos t 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 act ivity is the same as in prior periods. There may be** 7

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  **circumstances that may preclude consultation in a specific situation. These circumstances should be explained.**  A 60 and 30

- day

Federal Register Notice was published, the Department did not receive any public comments. OCTAE annually convene s a technical wo rk group (TWG) comprised of state representatives and representatives from adult literacy organizations. We obtain their TWG members views on accountability

policy issues and logistical aspects of the NRS data collection process, including the design and implementation of the collection itself
. The technical work group also informs the development of the regional NRS training offered annually to s tates. Additionally , OCTAE provides NRS information sessions at the annual meeting for adult education s tate d irectors and conducts webinars throughout the year related to the NRS implementation issues and data use
.

 **Explain any decision to provide any payment or gift to respondents, other than remunerati**  **on of contractors or grantees.** The respondents will not receive any pay ments or gifts for completing the information collection.

 **Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or**  **agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on**  **the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed**  **as indicated on the ICRAS’ Part 2 IC form. A confidentiality statement with a legal citation that authorizes the pledge**  **of confidentiality should be provided. Requests for this information are in accordance with the following ED and OMB policies: Privacy A**  **ct 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**  **Privac y 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 of Personally Identifiable Information). If the collection is subject to the Privac**  **y Act, the Privacy Act statement is deemed sufficient with respect to**  **confidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data.**  As proposed in this data collectio n extension, the data collected by states and submitted to the U.S. Department of Education will be aggregated data. It will not include any personally

identifiable information. Assurances of confidentiality to adult education participants are, therefore , not applicable to this collection.8

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education** 

 **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 incl ude 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.** None of th e data collected in the National Reporting System is sensitive in nature. **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, in**  **dividuals 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 estimate**  **d, including identification of burden type: recordkeeping, reporting or third party disclosure. All narrative should be included in Question 12. Unless**  **directed to do so, agencies should not conduct special surveys to obtain information on which to base h**  **our 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.** WIA and EDGAR require eligible agencies to submit Annual Performance Reports to demonstrate continuous imp rovement in the deliver y of their approved State Plan
. Because there are no major changes associated with this data collection extension proposal, OCTAE assumes that the burden hours in each of the next three years will be the same as the estimates used p reviously

– i.e., 100 hours per response. Although OCTAE has proposed a few minor changes in this data collection extension proposal , these changes are not likely

to add burden. For example, the change allowing states to report on a representative group when reporting on the follow

- up measures is likely to reduce burden. Additionally , the new table in the Federal Financial Report is not likely to add a new burden because states already collect this financial information. . The estimated average burden hours are 100 hours per response in each of the three years (2014

- 2017) for a total estimate of 5700 burden hours each year and a total estimate of 17,100 over the entire three years . Program Year Number of

Responses Ty

pe of Staff Average

Burden Hours per Response Total Average

Burden Hours for All Responses9

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  201 4
- 1 5 57 Professional Data Entry 8 0

2 0 = 10 0 hours 456 0

114 0

= 570 0 hours 201 5
- 1 6 57 Professional Data Entry 80

20 =100 hours 4560

1140 =5700 hours 201 6
- 1 7 57 Professional Data Entry 80

20

= 100 hours 4560

1140 =5700 hours

 **If this request for approval covers more than one form, provide separate hour burden estimates for each form. (The table should at minimum include Respondent**  **types, Number of Respondents and Responses, Hours/Response, and Total Hours)**  This data collection extension involves only one form.

 **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 Question 14.**  After slightly increasing the hourly rate of both labor categories from the rates used for this estimat e in 2011, the cost per response for the professional labor is $2,080 (80 hours times an hourly

rate of $26/hr) and the cost per response for the data entry is $300 (20 hours times an hourly

rate of $15/hr).
Program Year Ty

pe of Staff Average

Burden Hour s per Response Hourly

Rate Average Total Cost Per Response 2014
- 15 Professional

Data Entry 8 0

+ 2 0 10 0 hours $2 6

$1 5 $ 2,08 0

$30 0 $ 2,38 0 2015
- 16 Professional

Data Entry 80

+ 20 1 00 hours $26

$15 $ 2,08 0

$300 $ 2,38 0 2016
- 17 Professional

Dat a Entry 80

+ 20 100 hours $26

$15 $ 2,08 0

$300 $ 2,38 010

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  **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 Q**  **uestions 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 esti mates**  **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 lif**  **e 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, samp**  **ling, 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 us e 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 Oct**  **ober 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 priv**  **ate practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured**  **above in Question 12. Total Annualized Capital/Startup Cost:**  $0 **Total Annual Costs (O&M):** $0 **Total Annualized Costs Requested:** $0 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 nor 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 their costs are not included in this estimate. The total operation and maintenance and purchase of service components for this information is zero. The information collection will not create costs associated with11

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  generating, maintaining, and disclosing or providing the information that is not already identified in question 12 of this supporting statement. **14. Provide estimates of annualiz**  **ed 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 w**  **ould 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 Software Modifications**  There are costs to updating and maintaining the Federal data syste m through which states report the data. The total cost is estimated at $ 120,000 f or software revisions and testing. **Program Office Staff** The t otal estimated Federal cost for program office staff is $1 36,786.40 over three years and is calculated as foll ows:
Program Office Staff Estimated

Number of Hours Per Year FY 201 4

Hourly Rate Estimated Cost Per Year Total Cost for Three Years GS
- 1 3 GS
- 13 GS
- 14 440

240 320 $ 43.09

$ 43.09 $ 50.92 $ 18, 959.60

+ $ 10,341.60 + $ 16,294.40 $ 45,59 5.60 $ 56,878
. 80

+ $ 31,0 24.80 + $ 48,883.20 $ 136,7 86.80 The total Federal costs are estimated to be $2 56,786.80 over three years, with an average annual cost of $8 5,595.60 . This includes contractor beta testing and web site maintenance, and the salaries and expenses of program s taff who manage the process. The average annual Federal cost is calculated as follows: $ 120,000 .00 Software Modification Costs + $ 136,7 86.80 Federal Program Office Staff Costs $ 256, 786.80 Total Federal Costs for Three Years ÷ 3 Divided by 3 Years

= $ 85,5 95.60 Average Annual Federal Costs **15. Explain the reasons for any program changes or adjustments to #16f of the IC Data**  **Part 1 Form.**12

**[ICR No. 1219.24] 1830**  **- 0027**  **- Measures and Methods for the**  **Nat ional Reporting System for Adult Education**  There is a program change decrease of

- 12,350 burden hours associated with this data collection extension proposal ; the one - time implementation of changes to the follow

- up measures in 2011 has been completed. This extension incorporates no significant changes to the existing collection during the extension period. **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, complet**  **ion of report, publication dates, and other actions.** The results of the data collection are published in OCTAE’s annual report to Congress. There are no complex analy tic al techniques used for the publication of these statistical tables. The state

- level data are aggregated and presented for the entire country by performance measure. **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.** O CT AE i s not seeking exemption from displaying the expiration date. **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.