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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

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.

This is a request for extension without change; the collection of information (application 

for grants) is necessary to ensure that potential applicants provide the information 

necessary for the Department of Education to ascertain the eligibility of the applicant and 

determine the programmatic responsiveness and technical quality of the application. The 

Education Department General Administrative Regulations (EDGAR) at Part.74.12(b) 

stipulates that, in making competitive grant awards, applicants shall use the SF-424 series 

and those forms and instructions prescribed by the Secretary. The Individuals with 

Disabilities Education Act (IDEA), which provides the programmatic authority for this 

collection, requires that grant awards under these programs be made through competition. 

A copy of the IDEA statute is included with this request.

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 requested in the Grant Application Form will be used by the Department 

of Education program managers to determine the relative quality of grant applications. 

Peer reviewers will assist in this process by evaluating applications. Based on the peer 

review, applications are ranked and a decision is made by the recommending official as to 

award. 

 

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Please limit pasted text to no longer than 3 paragraphs.
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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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.

Applicants must submit applications electronically through Grants.gov.

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.

Information requested in the application is not available from any other source. 

Applicants must provide substantial information that is uniquely responsive to the grant 

announcement.

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 information does not significantly impact small business or other entities. 

In almost all grant programs included in this announcement, small businesses are not 

among the eligible applicants. In those few instances where they are eligible, the amount of 

information requested is not excessive, but rather is essential to determine the quality of 

the application.

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.

If the collection were not conducted, there would be no documentation for decisions to 

award grant funds. If the collection were conducted less frequently the Department would 

not have timely information on which to evaluate and rank applications. Technical and 

legal obstacles to reducing burden would emanate from the resulting lack of sufficient 
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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

information upon which to base the award of funds, which, by statute, must be awarded 

through competition.

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.

Applicants are required to submit applications electronically through Grants. Gov. 

However, an applicant can request an exception to the electronic submission requirement.

Applicants are reminded that current Government-wide policy requires that an original 

and two copies be submitted, however, applicants are requested to submit an original and 

five (5) copies of the application. The additional copies are required to provide sufficient 

copies for peer reviewers, and for administrative purposes including data entry and a copy 

for the project officer. If fewer copies were provided by the applicant, the Department 

would need to make additional copies of the application which would result not only in a 

delay of the peer review and grant award, but also in possible inequities in the review 

caused by errors on copying or collating of application materials Experience has shown 

that applicants prefer to send additional applications in order to benefit from earlier 

decisions and ensure that all application materials reviewed by the Department are in 

order.
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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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.

Consultation was not sought on the application package since it includes only necessary 

information for applicants and standard forms that are required for all application 

packages issued by the Department. A 30-day FRN was published. 

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

of contractors or grantees with meaningful justification.

Not applicable.

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.

 

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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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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

No assurance of confidentiality is provided to applicants. After awards are made, 

applications may be made available to all interested parties.

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.

Not applicable.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden was 

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. Unless directed to do 

so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary widely 

because of differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, estimates should 

not include burden hours for customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in 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.

Number of respondents: Estimated 800. Frequency of response: Once per year.

Annual hour burden: Average 25 hours per respondent; range from 20 to 50. The 

application package includes other OMB-approved forms that have their own data burden 

associated with them. The estimate of data burden provided above does NOT include the 

burden associated with the standard forms used under EDGAR. 

How the burden was estimated: Estimates provided by agency staff who have previous 
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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

work experience in State and local education agencies and universities, the primary eligible 

applicants under these programs. 

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

resulting from the collection of information. (Do not include the cost of any hour burden shown 

in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into account 

costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions 

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and 

usual business or private practices. 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 : None.

Total Annual Costs (O&M) : None.

____________________

Total Annualized Costs Requested : None.

Annualized cost to respondents: Average 25 hours x $40 per hour + $ 1,000 per 

respondent. (Assume average salary plus overhead and fringe benefit of $80,000)

Total for all respondents: 800 applications x $1,000 per respondent = $800,000.
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EDICS Tracking and OMB Number: (XXXX) 1820-0028 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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 staff costs: $135,000. (Assumes 1.5 FTE at GS 12)

Contractor support costs: $350,000

Peer review costs: $1,380,000. (Assumes 600 at $ 2,300 each) 

Supplies: $4,000

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).

Not applicable. Reinstatement without changes.

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.

None.

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.

Expiration date will be displayed.

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

Paperwork Reduction Act.

No exceptions requested.