OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB Number: 1845-0113

Table	of	Contents

A. Justification................................................................................................................................................................1

1. Explain the circumstances that make the collection of information necessary. ........................................................1

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

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;......................................................................................................................................................2

4. Describe efforts to identify duplication.....................................................................................................................2

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

used to minimize burden. ................................................................................................................................3

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is 

conducted less frequently................................................................................................................................3

7. Explain any special circumstances that would cause an information collection to be conducted in a 

manner: ...........................................................................................................................................................3

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..........................................................................................................................................4
OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

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

contractors or grantees with meaningful justification....................................................................................4

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

statute, regulation, or agency policy...............................................................................................................5

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. .................................5

12. Provide estimates of the hour burden of the collection of information...................................................................5

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from 

the collection of information...........................................................................................................................7

14. Provide estimates of annualized cost to the Federal government...........................................................................8

15. Explain the reasons for any program changes or adjustments................................................................................9

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..................................................10

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. ............................................................................10

18. Explain each exception to the certification statement identified in the Certification of Paperwork 

Reduction Act. ...............................................................................................................................................10
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OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

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 section1. 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.

The Higher Education Opportunity Act, Pub. L. 110-315, added provisions to the Higher Education Act, as 

amended (HEA) in sections 760 and 766 that enable eligible students with intellectual disabilities to 

receive Federal Pell Grant (Pell), Supplemental Educational Opportunity Grant (FSEOG), and Federal 

Work Study (FWS) funds if they are enrolled in an approved program.

Beginning with the 2011-2012 award year, the data began being submitted electronically through a 

module in the eCampus-Based system at http://cbfisap.ed.gov.

The program is continuing to grow with 34 institutions currently participating. Additional institutions have 

filed applications.

The data collected is used by the Department of Education (the Department) to monitor program 

effectiveness and accountability of fund expenditures. The data is used in conjunction with institutional 

program reviews to assess the administrative capability and compliance of the applicant. There are no 

other resources for collecting this data. Sections of the Higher Education Act of 1965, as amended, that 

govern these programs can be found at http://www2.ed.gov/about/offices/list/ope/library.html. 

The legislative authority governing the application for the distribution of these funds is:

 Pell Grant funds is 20 U.S.C. 1070a (34 CFR 690.12); 

 FWS funds it is 42 U.S.C. 2752 (34 CFR 673.3); 

 FSEOG funds it is 20 U.S.C. 107b-3 (34 CFR 673.3).

 

1

Please limit pasted text to no longer than 3 paragraphs.
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OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

The legislative authority governing the annual report on the uses made of funds provided under the 

previous sections is (20 U.S. C. 1094) enacted October 3, 1980, P.L. 96-374, sec. 451(a), 94 Stat. 1451; 

amended April 7, 1986, P.L. 99-272, sec. 16034, 100 Stat.356; amended October 17, 1986, P.L. 99-498, 

sec. 487(a), 100 Stat. 1486.

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 data reported reflects the relative institutional extent of participation in the program, the number of 

students enrolled in the program at each institution and the number of students receiving funds from each 

of the Pell, FSEOG and FWS programs. The data is used to asses the program effectiveness and 

accountability of fund expenditures under the previously cited authority. In addition, the data will be used 

in conjunction with institutional program reviews to help assess the administrative capability of the 

applicant and enforce compliance.

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.

Beginning with the 2011-2012 award year, the data began being submitted electronically through a 

module in the eCampus-Based system at http://cbfisap.ed.gov. 

The first year of data collection occurred for the 2010-2011 award year with expenditure reports due 

September 30, 2011. There were only seven institutions participating with approved programs so an 

OMB-approved form was not required. In order to collect the data in the short time allotted, the form was 

distributed to the participating institutions and hardcopy reports were returned to the Department by the 

deadline date. The number of applications increased to 10 participating institutions in 2011-2012 award 

year, to 16 in the 2012-2013 award year. There are currently 34 institutions participating. Additional

institutions have filed applications. The higher number of participants required an OMB-approved data 

collection. Having added a Comprehensive Transition Program for Students with Intellectual Disabilities 

(CTP-Intellectual Disabilities) module to the already stable and existing eCampus-Based System allowed

the Department to lessen the burden to both institutions and the Federal Government.

4.		Describe	efforts	to	identify	duplication. 
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Show specifically why any similar information already available cannot be used or modified for use for the 

purposes described in Item 2 above.

There is no duplication of data. The data is not collected in any other system or format.

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.

The collection of this information 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.

Also describe any technical or legal obstacles to reducing burden.

If the collection were done less frequently, reporting requirements for the specific programs would not be 

met.

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;
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OMB Number: 1845-0113 Revised: 12/05/2014

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 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.

There are no special circumstances inconsistent with these guidelines.

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 circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

The data is requested from participating institutions with approved programs. Sixty-day and 30-day 

Federal Register Notices are published to allow public comment. This filing is part of the 60 day comment 

period.

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

remuneration	of	contractors	or	grantees with	meaningful	justification.

There are no payments or gifts to respondents.
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10.	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 IC Data Form. A confidentiality statement with a legal citation that authorizes 

the pledge of confidentiality should be provided.2If 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.

The Department makes no pledge about the confidentiality of the data.

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.

This collection does not include information of a sensitive 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 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 

 

2

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)
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OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

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 the ROCIS IC Burden Analysis Table. (The table 

should at minimum include Respondent types, IC activity, Respondent and Responses, 

Hours/Response, and Total Hours)

 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.

There are a total of 34 respondents. The Office of Postsecondary Education has done everything 

possible to reduce the burden. 

Est. No. of 

Respondents

Est. Avg. Person 

Hours per 

Respondent –

Reporting

Est. Avg. Person 

Hours per Respondent 

– Record Keeping

Total Hours

Public Institutions 25 1 1 50

Proprietary & Private 

Institutions

9 1 1 18

Total 34 1 1 68

Average Salary of 

Respondents

Total Salary Cost of all 

Respondents

$26.90 per hour $1,829

(Total hours x Salary)
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OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

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 startup 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 Item 12

Total Annualized Capital/Startup Cost : $0

Total Annual Costs (O&M) : $0

____________________

Total Annualized Costs Requested : $0

The nature of business for the participating institutions is such that purchases of equipment and provision 

of services that are required for completion of their expenditure submissions are a part of their customary 

and usual business practice. They are the type of equipment and services normally necessary to 

successfully operate any institution of higher education. Therefore, no special equipment or services are 

required for providing data.
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OMB Number: 1845-0113 Revised: 12/05/2014

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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 matrix below describes the separate costs for CTP-Intellectual Disabilities. 

CTP-Intellectual Disabilities Publication and Distribution Costs

CTP-Intellectual Disabilities is incorporated into the eCampus-Based System web operations. There are no separate 

operations and maintenance or publication and distribution costs.

Total $0

CTP-Intellectual Disabilities Operations & Maintenance Contract Costs

Collabralink

8405 Greensboro Drive

Suite 1200

Falls Church, VA 22102

The current annual O&M costs for the eCB system include the FISAP and Reallocation forms1as well as the 

TCLI Directory2, Work Colleges Application and Expenditure forms3, and the CTP-Intellectual disabilities 

form4. 

1

The FISAP and Reallocation Form is a separate data collection with OMB control number 1845-0030

2

The TCLI Directory is a separate data collection with OMB control number 1845-0077.

3

The number of schools participating in the Work Colleges program is static at 7 participants. There is no 

OMB control number for this data collection.

4

The CTP form is a separate data collection with OMB control number 1845-0113.

Note:

Annual O&M Contract cost - $1,473,339 = monthly cost $122,778 allotted as:

FISAP (8 months) = $982,226

Reallocation (1 month) = $122,778

TCLI Directory (1 month) = $122,778

Work Colleges (1 month) = $122,778

CTP-Intellectual Disabilities (1 month) = $122,778

Total CTP-Intellectual Disabilities O&M Costs (1 month) $122,778.26
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OMB Number: 1845-0113 Revised: 12/05/2014

2014-2015 Financial Assistance for Students with Intellectual Disabilities Expenditure Report (eCB 16.0)

CTP-Intellectual Disabilities Staffing Operations and Overhead Costs

A staff of 8.5 FTE’s is required for the operation of the campus-based programs and the eCB system. This includes the 

FISAP and Reallocation forms as well as the TCLI Directory, Work Colleges Application and Expenditure forms, and the 

CTP-Intellectual disabilities form as footnoted above. The types of program staff include managers, accountants, 

financial management specialists, technicians, systems analysts, and clerical staff. The total amount of annual salaries 

devoted to eCampus-Based activities is $1,354,102.

Using the Salary Table 2014-DCB Effective January 2014, the average hourly wage of the current staff composition is 

$51.02. 

Note:

The total amount of annual salaries devoted eCB activities is divided as:

Reallocation (3 staff @ 120 hrs ea x $46.94) = $18,366.92

TCLI Directory (1 staff @ 80 hrs x $46.94) = $4,081.54

Work Colleges (1 staff @ 160 hrs x $46.94) = $8,163.08

CTP-Intellectual Disabilities (1 staff @160 hrs x $46.94) = $8,163.08

FISAP (Total salaries less Reallocation, TCLI Directory, Work Colleges, CTP-Intellectual Disabilities) = $1,402,249.38

CTP-Intellectual Disabilities Yearly Staff Costs $8,163.08

CTP-Intellectual Disabilities Yearly Overhead Costs

A standard budget estimate of 16% was used to determine the overhead costs of staff operations including such items 

as equipment, utilities, work materials, etc. ($8,163.08 x 16% = $1,201.73)

Yearly Overhead Costs $1,306.09

Total Staff and Overhead Costs to the Federal Government $9,469.17

15.	Explain	the	reasons	for	any	program	changes	or	adjustments.

Generally, adjustments in burden result from re-estimating burden and/or from economic phenomenon outside 

of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting 

universe). Program changes result from a deliberate action that materially changes a collection of information 

and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, 

redefining the respondent universe, etc.). Burden changes should be disaggregated by type of change (i.e., 

adjustment, program change due to new statute, and/or program change due to agency discretion), type of 

collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals 

for changes in burden hours, responses and costs (if applicable).

This is a request for an extension of the current information collection. There have been no changes in 

the underlying regulations. The increase in burden is due to the expansion of the number of participating 
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OMB Number: 1845-0113 Revised: 12/05/2014

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institutions. The annual reporting and record keeping hour burden has not changed from the current 

OMB inventory of 2 hours per respondent. 

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.

This information collected in CTP-Intellectual Disabilities is not collected for statistical publication.

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 is not seeking this approval.

18.	Explain	each	exception	to	the	certification	statement	identified	in	the	Certification	of	

Paperwork	Reduction	Act.

There are no exceptions to the certification statement.