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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

National Reporting System for Adult Education

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

National Reporting System for Adult Education

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, 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 changes. 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 Federal 

government, States, 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 eligible agencies in 

achieving continuous improvement of adult education and literacy activities in order to 

optimize the return on the Federal investment. 

Title II of the Workforce Innovation and Opportunity Act (WIOA – P.L. 113-128), was 

enacted on July 22, 2014 and becomes effective on July 1, 2015. The current WIA 

accountability requirements of the National Reporting System (NRS) will remain in effect 

until new requirements under WIOA 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.

These measures are referred to in AEFLA as “core indicators”:

1. demonstrated improvements in adult learners’ literacy skill levels;

2. placement in, retention in, or completion of postsecondary education, training,

unsubsidized employment or career advancement; and

3. receipt of a secondary school diploma or its recognized equivalent.

 

1 AEFLA can be found at the following link:

http://www.gpo.gov/fdsys/pkg/PLAW-105publ220/html/PLAW105publ220.htm
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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

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States submit 10 required tables, 6 optional tables, 4 financial reports, 1 narrative report, 

and 1 data quality checklist. These table and report forms are included in the document 

named “Instrument.” States include in the tables all participants in programs:

1. that meet the purposes of AEFLA, and

2. for which 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) requires each eligible agency to report annually to the Secretary on its

progress in achieving its targets, including information 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 State 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 

consider eligible agency performance on the core indicators of performance in awarding 

performance incentive grants to States (Section 503).

Two other legislative and regulatory statutes 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 requires each Federal agency 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 Literacy 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. 

OCTAE plans to obtain this information from this data collection extension package. 

The Education Department General Administrative Regulations (EDGAR). In addition to 

the accountability requirements contained in AEFLA, EDGAR requires grantees to submit

performance reports not more frequently than quarterly or less frequently than annually (34 

CFR 80.40). Those regulations also require grantees to submit financial status reports not 

more frequently than quarterly or less frequently than annually (34 CFR 80.41).

In 2014, OMB most recently approved the data collection required by AEFLA (OMB 1830-

0027). OCTAE is requesting an extension of this approval. As proposed here, this 

collection contains minor changes from the collection approved in 2014. These changes are 

described below:

In 2011, OMB approved 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 a 
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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

National Reporting System for Adult Education

result of 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 definitions

enlarged the size of the cohorts for reporting purposes. It also gave states the option of 

using a representative group of cohort members to determine whether they have met the 

outcome measure. This option reduces the data collection burden for those states that elect 

to use it.

In 2014, OCTAE released several new automatic validation functions in its web-based 

reporting system used for this data collection. These new automatic validation functions 

give states immediate notice of any discrepancy in the data they enter, allowing a state 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 states 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 performance 

reporting purposes. The educational gains indicate whether a program is moving 

participants toward a post-secondary credential or employment. 

As proposed here, the modified learning objectives, known as descriptors, will help 

modernize the accountability system to reflect the adult educational demands of the 21st

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 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.

OCTAE uses the information received from the current collection to fulfill 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 

levels 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
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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

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WIA Section 243 requires ED to provide technical assistance to states and evaluate the 

effectiveness of local programs. ED will use the information reported to identify which 

states 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 OCTAE’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 State’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.

In addition to the purposes above, OCTAE has used the information from this data 

collection extension proposal for its monitoring efforts and for budget justification.

GPRA 

GPRA requires 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. OCTAE’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 follow-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 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.

Over the past several years, States have developed individual student record systems using 

relational databases to track students and to meet reporting requirements within the 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 collection 

extension proposal through their individual student record systems and submit this 

information to OCTAE electronically. To assist States in electronic reporting, in 2004,

OCTAE created a web-based database system known as the National Reporting System for 
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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

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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 system automates the process by which States collect, compile, and 

report the data and results in a paperless annual reporting system.

The electronic compilation and annual submission of these data makes the collection more 

efficient and accurate. Rather than compiling individual paper reports from each local 

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 functions, 

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 similar 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. If 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 jurisdiction, 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. If the collection did not occur, ED would be unable to comply

with several statutory mandates, including the requirement in Section 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 Section 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. 
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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

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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.

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), 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 
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[ICR No. 1219.24] 1830-0027 - Measures and Methods for the 

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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 convenes a technical work 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 states. 

Additionally, OCTAE provides NRS information sessions at the annual meeting for adult 

education state directors 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 

remuneration of contractors or grantees.

The respondents will not receive any payments 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 Act 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 

Privacy 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 Privacy 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 collection 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.
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 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.

None of the 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, 

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 Question 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.

WIA and EDGAR require eligible agencies to submit Annual Performance Reports to 

demonstrate continuous improvement in the delivery 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 previously – 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 Type of Staff

Average 

Burden 

Hours per 

Response

Total Average

Burden Hours

for All 

Responses
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2014-15 57 Professional 

Data Entry

80

20

= 100 hours

4560

1140

=5700 hours

2015-16 57 Professional

Data Entry

80

20

=100 hours

4560

1140

=5700 hours

2016-17 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 estimate 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 Type of Staff

Average 

Burden Hours 

per Response

Hourly Rate

Average 

Total Cost 

Per 

Response

2014-15 Professional 

Data Entry

80

+ 20

100 hours

$26

$15

$2,080

 $300

$2,380

2015-16 Professional

Data Entry

 80

+ 20

100 hours

$26

$15

$2,080

 $300

$2,380

2016-17 Professional

Data Entry

 80

+ 20

100 hours

$26

$15

$2,080

 $300

$2,380
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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 Questions 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and startup 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. 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 with 
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generating, maintaining, and disclosing or providing the information that is not already

identified in question 12 of this supporting statement.

14. Provide estimates of annualized cost to the Federal government. Also, provide a 

description of the method used to estimate cost, which should include quantification of 

hours, operational expenses (such as equipment, overhead, printing, and support staff), 

and any other expense that would not have been incurred without this collection of 

information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a 

single table.

Federal Software Modifications

There are costs to updating and maintaining the Federal data system through which states 

report the data. The total cost is estimated at $120,000 for software revisions and testing. 

Program Office Staff

The total estimated Federal cost for program office staff is $136,786.40 over three years 

and is calculated as follows:

Program 

Office Staff

Estimated

Number 

of

Hours

Per Year

FY 2014

Hourly Rate

Estimated Cost

Per Year

Total Cost 

for Three 

Years

GS-13

GS-13

GS-14

440

240

320

$43.09

$43.09

$50.92

 $18,959.60

+$10,341.60

+$16,294.40

$45,595.60

 $56,878.80

+$31,024.80

+$48,883.20

$136,786.80

The total Federal costs are estimated to be $256,786.80 over three years, with an average 

annual cost of $85,595.60. This includes contractor beta testing and web site 

maintenance, and the salaries and expenses of program staff who manage the process. 

The average annual Federal cost is calculated as follows:

$120,000.00 Software Modification Costs

+ $136,786.80 Federal Program Office Staff Costs

$256,786.80 Total Federal Costs for Three Years

÷ 3 Divided by 3 Years

= $85,595.60 Average Annual Federal Costs

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

Part 1 Form.
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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, completion 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 analytical 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.

OCTAE is 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.