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EDICS Tracking and OMB Number: (XXXX) 1840-0604 Revised: xx/xx/xxxx

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.

The Graduate Assistance in Areas of National Need (GAANN) program, authorized 

under 20 U.S.C. 1135, provides grants to departments and programs of higher education 

to support graduate fellowships for students of superior ability who demonstrate financial 

need. The authorizing statute for GAANN (Title VII, Part A, Subpart 2 of the Higher 

Education Act of 1965, as amended) requires the collection of specific data that are 

necessary for applicant institutions to receive an initial competitive grant and noncompeting continuation grants for the second and third years. The current application 

(OMB #1840-0604) expired on June 30, 2014. The U.S. Department of Education 

(Department) is now requesting a reinstatement without change of this collection package 

to collect data under 34 CFR Sections 648.20, 648.31, and 648.66. The link to the 

statute: (http://www.law.cornell.edu/uscode/text/20/chapter-28/subchapter-VII/partA/subpart-2)

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 Department uses the data collected in the Application for New Grants to evaluate, 

score, and rank the quality of the projects proposed by the institutions of higher education 

applying for a grant. Data are also used to determine allowable multi-year project 

expenses based on statutory requirements, and to recommend funding levels for the 

proposed grants. If the data are not collected, the Department could not determine the 

quality of competing applications, which is the basis for making grant awards as required 

by the statute.

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 

 

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Please limit pasted text to no longer than 3 paragraphs.
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EDICS Tracking and OMB Number: (XXXX) 1840-0604 Revised: xx/xx/xxxx

RIN Number: XXXX-XXXX (if applicable)

decision of adopting this means of collection. Also describe any consideration given to using 

technology to reduce burden.

The GAANN program participates in the Grants.gov application submission process. 

The GAANN application is available only through Grants.gov. Through Grants.gov, 

applicants are able to build and submit their proposals offline and then submit them 

electronically. 

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.

Since the information submitted in the application is specific to the GAANN program, 

there is no duplication. There is no other collection instrument available to collect the 

information necessary to meet the purposes described in item 2 above.

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.

Institutions of higher education are the sole recipients of GAANN grants. There is no 

impact on small businesses or small entities.

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.

Grants awarded under this program are made annually and the data must be collected for 

each new competition cycle. Failure to collect this information would prohibit the 

Department from fulfilling its responsibility to award grants under this program.

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;
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EDICS Tracking and OMB Number: (XXXX) 1840-0604 Revised: xx/xx/xxxx

RIN Number: XXXX-XXXX (if applicable)

 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.

There are no special circumstances as outlined in #7 of the instructions.

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.

A 30-day notice for public comment will be published in the Federal Register. Program 

staff will respond to any questions or comments resulting from the publication of the 

information collection in the Federal Register as required by 5 CFR 1320.8(d).

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

contractors or grantees with meaningful justification.

No gifts or payments will be provided to respondents.

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 
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EDICS Tracking and OMB Number: (XXXX) 1840-0604 Revised: xx/xx/xxxx

RIN Number: XXXX-XXXX (if applicable)

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.

There are no assurances of confidentiality provided.

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.

Questions of a sensitive nature are not included in this information collection.

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 

 

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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) 1840-0604 Revised: xx/xx/xxxx

RIN Number: XXXX-XXXX (if applicable)

activities should not be included here. Instead, this cost should be included in Item 

14.

The estimated total reporting burden for this data collection is 13,432 hours. This 

includes a total of 325 respondents (227 public universities and 98 private universities), 

each with an estimated response time of 41.33 hours. 

Public Universities Private Universities

Estimated number of respondents 227 98

Estimated response time 41.33 41.33 

Frequency of collection 1 annually 1 annually

Total estimated burden hours 9,382 4,050

The burden to each individual respondent, established at 41.33 hours, is based on 

feedback from respondents during previous competitions.

The estimated annual cost to a single respondent is as follows: 

Public Universities Private Universities

Professional staff (35 hrs x $35 per hour) $1,225 $1,225

Clerical staff (6.33 hrs x $10 per hour) $63.30 $63.30

Total estimated cost per respondent $1,288.30 $1,288.30

Total estimated costs to all 325 

respondents (227 public universities x 

$1,288.30) and (98 private universities x 

$1,288.30)

$292,444.10 $126,253.40

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), 
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EDICS Tracking and OMB Number: (XXXX) 1840-0604 Revised: xx/xx/xxxx

RIN Number: XXXX-XXXX (if applicable)

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 : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

The total for the capital and start-up cost components for this information collection is 

zero. This information collection will not require the purchase of any capital equipment

and will not create any start-up costs.

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.

Estimated cost to the Federal Government:

Task Cost Hours Number of 

Staff

Hours 

Total

Total Cost

Securing OMB approval once every 3 years. $42/hr 15 4 60 $2,520

Reports Design (every 3 years) $42/hr 20 3 60 $2,520

Sorting applications, forming review panels, 

assigning proposals

$42/hr 320 3 960 $40,320

Conducting Reviews $42/hr 200 3 600 $25,200

Generate/Preparing Slates $42/hr 40 3 120 $5,040

Slate Review and Approval $55/hr 5 6 30 $1,650

Issuance of Awards $42 100 2 200 $8,400

Monitoring and Technical Assistance $42 500 2 1000 $42,000

Total Annual Cost $127,650

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 
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EDICS Tracking and OMB Number: (XXXX) 1840-0604 Revised: xx/xx/xxxx

RIN Number: XXXX-XXXX (if applicable)

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 reinstatement without changes of a previously approved collection. The 

previous collection was discontinued; therefore, all burden is new. 

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.

Results of the collected information will not be published.

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.

This report will display the expiration date for the OMB approval of the information 

collection.

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

Reduction Act.

There are no exceptions to the certification statement.