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Race to the Top – District Annual Performance Report:

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

A.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.

On February 17, 2009, President Barack Obama signed into law the American Recovery

and Reinvestment Act of 2009 (ARRA), historic legislation designed to stimulate the 

economy, support job creation, and invest in critical sectors, including education. The 

ARRA established the foundation for education reform by supporting investments in 

innovative strategies that are most likely to lead to improved results for students, longterm gains in school and school system capacity, and increased productivity and 

effectiveness. The ARRA initially provided $4.3 billion for the Race to the Top Fund 

(referred to in the statute as the State Incentive Grant Fund) to support a State education 

reform program (Race to the Top State grants).

In 2010, the United States Department of Education (Department) conducted Race to the 

Top State competitions, which provided incentives to States to adopt bold and 

comprehensive reforms in elementary and secondary education and laid the foundation 

for unprecedented innovation. A total of 46 States and the District of Columbia put 

together plans to implement college- and career-ready standards, use data systems to 

guide teaching and learning, evaluate and support teachers and school leaders, and turn 

around their lowest-performing schools. The Race to the Top State competitions 

provided States with incentives to implement large-scale, system-changing reforms 

designed to improve student achievement, narrow achievement gaps, and increase 

graduation and college enrollment rates. 

The Race to the Top Assessment program, also authorized under the ARRA, supports 

consortia of States in developing new and better assessments aligned with high standards.

In 2011, the ARRA was amended by section 1832(b) of Division B of the Department of 

Defense and Full-Year Continuing Appropriations Act, 2011 (Pub. L. 112-10), which 

added an additional education reform area: strengthening the quality of early learning 

and development programs and increasing access to high-quality early learning programs 

for all children, including those with high needs. As a result, the Department had the 

authority to use a portion of the FY 2011 and FY 2012 appropriations for Race to the Top 

on the Race to the Top-Early Learning Challenge program, which is jointly administered 

by the Departments of Education and Health and Human Services. The Race to the Top-
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Early Learning Challenge supports 14 States’ efforts to strengthen the quality of their 

early learning programs.

On December 23, 2011, the ARRA was amended by the Department of Education (Title 

III of Division F of Pub. L. 112-74, the Consolidated Appropriations Act, 2012) to allow 

the Department to make grants directly to LEAs. On May 22, 2012, the Secretary

announced the Race to the Top – District program, which is designed to build on the 

momentum of other Race to the Top competitions by encouraging bold, innovative 

reform at the local level. This district-level program is authorized under sections 14005 

and 14006 of the ARRA, as amended. Congress appropriated approximately $550 

million for Race to the Top for FY 2012. Of these funds, the Department awarded 

approximately $383 million to 16 Race to the Top – District grantees representing 55 

local educational agencies (LEAs), with grants ranging from $10 to $40 million. The 

amount of the award for which an applicant was eligible to apply depended upon the 

number of students who would be served under the application.

The FY 2013 Race to the Top – District competition will again support applicants that 

demonstrate how they can personalize education for all students in their schools. The 

priorities, requirements, definitions, and selection criteria used in the FY 2013 

competition are almost identical to those used in the FY 2012 competition. The 

application submission period for the FY 2013 Race to the Top – District competition 

closed on October 3, 2013. LEAs located in Colorado counties designated for Individual 

Assistance or Public Assistance under the Presidential major disaster (DR-4145) or 

emergency (EM-3365) declarations resulting from the September 2013 severe storms, 

flooding, landslides, and mudslides had an extended deadline of October 10, 2013. 

Applications are currently under peer review and the Department plans to make awards in 

December 2013 for a total of approximately $120 million. FY 2013 grantees will utilize 

the same Annual Performance Report (APR) template as FY 2012 Race to the Top –

District grantees.

The Race to the Top – District program is aimed squarely at classrooms and the allimportant relationship between educators and students. The Department encouraged and 

rewarded those LEAs or consortia of LEAs that have the leadership and vision to 

implement the strategies, structures, and systems needed to implement personalized, 

student-focused approaches to learning and teaching that the Department believes will 

produce excellence and ensure equity for all students. To support Race to the Top –

District grantees as they implement ambitious reform agendas, the Implementation and 

Support Unit (ISU) at the Department is dedicated to differentiating its approach to 

supporting grantees based on individual district needs, as well as supporting districts to 

work with each other and with experts from around the nation to achieve and sustain 

educational reforms.

In order to fulfill our responsibilities for programmatic oversight and public reporting, the 

Department has developed a Race to the Top – District Annual Performance Report

(APR) that is tied directly to the FY 2012 and FY 2013 Race to the Top – District 

selection criteria and priorities previously established and published in the Federal 
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Register. The report is grounded in the key performance targets included in grantees’ 

approved Race to the Top – District plans. Grantees will be required to report on their 

progress improving student outcomes and implementing personalized learning 

environments, including narrative sections on progress and key performance indicators. 

Each grantee district will submit a Race to the Top – District APR on an annual basis. 

The first report for the 16 FY 2012 districts is anticipated to be collected during spring 

2014 with FY 2013 grantees reporting for the first time in spring 2015. Districts will 

submit the narrative elements and quantitative measures via an online data collection 

platform that will then be converted into a transparent public display. 

Grantee responses will provide the information required for the Department to fulfill its

programmatic and fiscal oversight responsibilities. In particular, the data will help to 

inform customized technical assistance for grantees.

The questions included in the APR relate to the grant administration/performance and are 

covered by the ARRA and Education Department General Administrative Regulations 

(EDGAR) provisions. Additionally, 34 CFR 80.20 requires that a grantee must account 

for grant funds in accordance with State laws and procedures. It also requires that a 

grantee’s fiscal control and accounting procedures, as well those of its subrecipients and 

contractors, must, among other things, be sufficient to permit the tracing of expenditures 

of funds to a level that ensures that funds have not been used in violation of applicable 

Federal requirements. Similarly 34 CFR 80.40 requires that grantees are responsible for 

managing the day-to-day activities of grants to assure compliance with Federal 

requirements and that performance goals are being achieved. In the Race to the Top –

District application, the Department asked grantees to create annual targets for 

performance measures and noted that additional measures may be added in the future.

A.2. Indicate how, by whom, and for what purpose the information is to be used. Except 

for a new collection, indicate the actual use the agency has made of the information 

received from the current collection.

The information collected will be in the form of an annual report on progress and key

performance indicators reported by grantee districts.

The Department will use information collected through the APR to assess the progress of 

Race to the Top – District grantees in implementation toward the targets outlined in their 

approved plans and to ensure compliance with statutory and Department fiscal 

regulations.

A.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 
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the basis for the decision of adopting this means of collection. Also describe any 

consideration of using information technology to reduce burden.

The Department has enlisted the services of a contractor to develop an electronic system 

to facilitate the collection of APR data from grantees. The system will reduce burden to 

grantees by prompting LEAs to complete the sections required based on their approved 

plans. For example, when a grantee logs in to complete its report, the system will direct 

the grantee specifically to complete only those elements that are required based on its

approved plan, will skip those sections that are not relevant, and will indicate when 

additional reporting is optional. 

The Race to the Top – District APR will be emailed to grantees, discussed on a webinar, 

and posted on the Department’s website. 

A.4. Describe efforts to identify duplication. Show specifically why any similar 

information already available cannot be used or modified for use of the purposes 

described in Item 2 above.

The assurances and information requested under this collection are unique to each year of 

the Race to the Top – District program, and the Department has not collected them in the 

past. Even in the event of similar or comparable information collected for other programs 

in the past, the progress updates and performance measures are specific to the Race to the 

Top – District program and the information is specific to the present point in time. 

Therefore, any comparable information and assurances that were collected in the past 

would not satisfy the requirements for this program.

The Department has made every effort to reduce the burden on grantees in providing the 

information. Some data are prepopulated in the system to reflect prior reporting (e.g., 

[Prepopulated from application]), to reduce grantee burden and utilize records already on 

file with the Department (e.g., [Prepopulated from CCD Data]), and to leverage existing 

Department data collections (e.g., [Prepopulated from EDFacts Data]).

A.5. If the collection of information impacts small businesses or other small entities 

(Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The eligible applicants for the Race to the Top – District program are LEAs or 

consortiums of LEAs. No small businesses will be directly impacted by this collection. 

In order to reduce the burden on small LEAs, the Department has made every effort to 

ensure that the required collection is absolutely necessary to meet the requirements of the 

program. Additionally, all LEAs were informed through the application process of the 

need to collect data on the performance measures included in their approved Race to the 

Top – District plans. 
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A.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.

This collection is critical to ensure the Department has the required information to inform 

ongoing performance management discussions with grantees in order to make the 

necessary and immediate adjustments to program implementation and support, as well as 

provide appropriate and timely updates to the public on the progress of grantees’ program 

implementation and achievement of targeted outcomes.

A.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 which 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.

The Department is committed to supporting LEAs as they implement ambitious reform 

agendas through Race to the Top – District. Specifically, the ISU is differentiating its 

approach to supporting grantees based on individual district needs and tailored technical 

assistance that supports districts to work with each other and with experts from around 

the nation to achieve and sustain educational reforms. Thus, ongoing communication 

with the Department is necessary to provide appropriate and timely assistance to districts

as they implement their Race to the Top – District plans. 

This collection is consistent with 5 CFR 1320.5(d)(2).

A.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 
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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 60 day notice was published on February 10, 2014 (74 FR 77109). A 30-day notice for 

public comment was published in the federal register. No public comments were 

received.

A.9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees.

No payments or gifts to respondents have been made.

A.10. Describe any assurance of confidentiality provided to respondents and the basis for 

the assurance in statute, regulation, or agency policy.

There is no assurance of confidentiality.

A.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.

There are no questions of a sensitive nature.

A.12. Provide estimates of the hour burden of the collection of information. 

A. Burden hours for respondents
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The Department estimates that each FY 2012 and FY 2013 grantee will spend between 43

and 63 hours of staff time to provide the information required in each APR. The lower 

level estimate is 43 hours, which represents the time needed to report on the required 

performance measures. The upper level estimate applies to grantees that have optional 

budget supplements and multiple project budgets; in that case, up to 20 additional hours 

will be needed to complete the report.

FY 2012 Race to the Top– District grantees were permitted to apply for optional budget 

supplements as part of their Race to the Top – District applications and several applicants 

chose to do so. Additionally, applicants were able to determine the number of project 

level budgets as part of their application. The time required to complete the APR beyond 

the 63 hour estimate depends on the project level budgets included in LEA applications, 

but we expect such reporting will require no more than 20 additional hours.

The spring 2014 APR will only include the 16 FY 2012 grantees. The total number of 

hours estimated to be spent nationally completing the APR in spring 2014 for FY 2012 

grantees would be 848 hours. This calculation is based on the sum of 16 times the 

average range for grantees (53 hours). FY 2013 grantees will report for the first time 

using the same APR template in spring 2015. The Department estimates 5 FY 2013 Race 

to the Top – District grantees, making an estimated total of 21 respondents for the spring 

2015 APR. The total number of hours estimated to be spent nationally completing the 

APR in spring 2015 would be 1,113 hours. This calculation is based on the sum of 21 

times the average range for grantees (53 hours). 

Sections Hours (Annual)

A. Vision: 

(A)(1) Articulating a comprehensive and coherent reform vision 0

(A)(2) Applicant's approach to implementation 2

(A)(3) LEA-wide reform & change 0

(A)(4) LEA-wide goals for improved student outcomes 5

B. Prior Record of Success and Conditions for Reform

(B)(1) Demonstrating a clear track record of success 0

(B)(2) Increasing transparency in LEA processes, practices, & 

investments 0

(B)(3) State context for implementation 0

(B)(4) Stakeholder engagement and support 0

(B)(5) Analysis of needs and gaps 0

C. Preparing Students for College and Careers

(C)(1) Learning 0

(C)(2) Teaching and Leading 0

D. LEA Policy and Infrastructure

(D)(1) LEA practices, policies, rules 1
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(D)(2) LEA and school infrastructure 0

E. Continuous Improvement

(E)(1) Continuous improvement process 0

(E)(2) Ongoing communication and engagement 0

(E)(3) Performance measures 15

(E)(4) Evaluating effectiveness of investments 0

F. Expenditures

(F)(1) Overall Budget 3

(F)(2) Project budget(s) 1

G. Optional Budget Supplement

Progress in implementing optional budget supplement project 2

Application Assurances

Progress in implementing application assurances 2

Competitive Preference Priority

Performance Measures 10

Absolute Priority 1

Progress in implementing personalized learning environments 2

Total annual hours minimum range 43

Total annual hours maximum range 63

B. Cost to Respondents

The Department estimates that the per-hour cost for grantee employees will average $30 

per person (approximately GS-12 equivalent) per hour for a total of $1,590 per grantee.

A.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 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 record 

storage facilities.
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 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: 0

Total Annual Costs (O&M): 0

_________________________________________

Total Annualized Costs Requested: 0

There are no start-up or annual costs (aside from salaries listed above) for this collection.

A.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 Federal costs do not include salaries of existing Federal staff. Costs explicated below 

are related solely to contractual support for the APR system maintenance. Specifically, 

the contractor will provide an online system for Annual Performance Report submission; 

provide technical assistance, as needed to grantees in using the system; conduct data 

quality reviews and work with grantees, as necessary; and conduct and analysis of this 

annual data. The contractor will submit an annual analysis of the data reported through 

the APR as well as cumulative progress on several metrics by district.

Contractor assistance $1,050,000

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

Part 1 Form.

This is a new collection – therefore all burden is new. This results in a program change of 

21 responses and 1,113 burden hours.
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A.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 Department will report the information to Congress within six months of the 

deadline for the submission of district reports to the Department. Some of the information 

collected in this Annual Performance Report may be analyzed with monitoring (program 

review) data, and other Department data sources, and shared on a government websites

such as ed.gov.

A.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.

There are no exceptions to the certification statement. The expiration date will be 

displayed on the form.

A18. Explain each exception to the certification statement identified in Item 20, 

“Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL 

METHODS

This information collection does not employ statistical methods.