1

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

ICRAS ICR ID and OMB Number: (1269.16) 1840-0595

Revised 05/22/2013

RIN Number: Not Applicable

05/22/2013 A. Baird (TSA Program Sponsor) to ICRAS 

A. Justification 

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

legal or administrative requirements that necessitate the collection. Attach a hard copy of 

the appropriate section of each statute and regulation mandating or authorizing the collection 

of information, or you may provide a valid URL link or paste the applicable section. Please 

limit pasted text to no longer than 3 pages. Specify the review type of the collection (new, 

revision, extension, reinstatement with change, reinstatement without change). If revised, 

briefly specify the changes. If a rulemaking is involved, make note of the sections or 

changed sections, if applicable.

Response: This request is for approval of reporting requirements that are contained 

in the Federal Family Education Loan Program (FFELP) regulations (34 CFR 

682.210) which address the targeted teacher deferment provision of the Higher 

Education Act of 1965 as amended by the Higher Education Amendment of 1986, 

sections 427(a)(2)(C)(vi), 428 (b)(1)(M)(vi), and

428 (b)(4)(A), which provide for the targeted teacher deferment.

The FFELP (34 CFR 682.210(q)), TEACH Grant Program (34 CFR 686), and Federal

Perkins Loan Program (34 CFR 674.53(c)) regulations contain information collection 

requirements. The Chief State School Officers (CSSOs) of each State provide the Secretary

annually with a list of proposed teacher shortage areas for that State.

If a State does not submit the required written documentation proposing teacher 

shortage areas, FFEL/SLS and Federal Perkins Loan borrowers and TEACH Grant 

recipients who teach in the State may not receive Federal program benefits to 

which they may be entitled.

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.

Response: The information collected is necessary for a State to support its 

annual request for designation of teacher shortage areas within the State.

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 
2

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

using technology to reduce burden.

Response: State education agencies are encouraged to submit the required annual data and 

supporting information 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 Question

2 above.

Response: A single designated agency in each State is responsible for providing 

the targeted teacher shortage area proposal. There is no duplication of records that 

the State agencies must maintain.

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.

Response: The information collection has no significant impact on small 

businesses or the 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.

Response: Loan borrowers and TEACH grantees will not be able to receive the loan 

deferment, cancellation/discharge of their loan debt, or meet their teaching 

obligation if the teacher shortage area information is not collected from the State and 

designated by the Department.

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;
3

 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.

Response: There are no special circumstances.

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.

Response: We have consulted with the Chief State School Officers and have received 

their input on the requirements associated with this collection. We will publish the 

required 60 and 30-day Federal Register Notices seeking public comment.

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

of contractors or grantees with meaningful justification.

Response: Not applicable. No gifts nor any payments are 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 for the Systems of Record Notice and the date a Privacy Impact 

Assessment was completed as indicated on the ICRAS’ Part 2 IC form. A confidentiality

statement with a legal citation that authorizes the pledge of confidentiality should be 

provided. Requests for this information are in accordance with the following ED and OMB 

policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation –

Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency

Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB 

M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 

1974 (Collection, Use and Protection of Personally Identifiable Information). If the 
4

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 confidentiality of the data. 

Response: The information is not of a personal and confidential nature, and no 

assurance of confidentiality is provided. The purpose of the collection is to designate 

teacher shortage areas and to distribute that information to loan administrative 

officials in the State Education Agencies. The information can also benefit (upon 

request) recent graduates of Schools of Education and trained, experienced teaching 

professionals aiming to serve school districts with shortage areas that match their 

certification credentials; and notify Federal financial aid recipients about reducing, 

deferring, or discharging student loan payments and meet other specified obligations. 

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.

Response: There are no questions 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 Question 12. Unless directed to do so, 

agencies should not conduct special surveys to obtain information on which to base 

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

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

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

burden, and explain the reasons for the variance. Generally, estimates should not 

include burden hours for customary and usual business practices.

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

estimates for each form. (The table should at minimum include Respondent types, 

Number of Respondents and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections 

of information, identifying and using appropriate wage rate categories. The cost of 

contracting out or paying outside parties for information collection activities should not 

be included here. Instead, this cost should be included in Question 14.

Response: This information clearance request covers only one form for the annual 

collection of information to update the Teacher Shortage Nationwide Report - 1840-0595. 

The form is a letter to each Chief State School Officer (an instructional guideline
5

document), explaining the required annual data and supporting information to submit to 

U.S. Department of Education by a specific deadline.

There are a total of 57 respondents to this annual information collection. The 

burden estimate for this information collection is 80.0 hours per respondent. 

Therefore the total annual burden is calculated as follows:

80.0 hours x 57 respondents = 4,560 total hours 

The hourly estimate includes identifying and collecting the relevant information, 

formatting and preparing the report response, securing appropriate signatures, and 

maintaining records.

The total annual cost burden to respondents is calculated as follows:

Professional Staff (80.0 hours@$16.35/hour)-------------- $1,308.00

Support Staff ($11.00/hour x 4.0 hours) $44.00

Estimated annual total cost for computer usage--------- $55.00

$1,407.00

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

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

shown in Questions 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and 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 Question 12.

Total Annualized Capital/Startup Cost:
6

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

Response: No additional costs to the States (the respondents and recordkeepers) are 

involved.

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 Questions 12, 13, and 14 

in a single table.

Response: The annual cost to the Federal Government for the State Teacher 

Shortage Area (TSA) proposals is estimated to be $15,705. This cost includes 

staff time in (1) preparing, printing, and mailing the solicitation for proposals; 

(2) reviewing the submission by the States; (3) recording and analyzing the 

information and methods used to determine the TSA. This step is necessary to 

ensure State compliance with the program statute and regulations; and (4) 

preparation and posting of the updated nationwide listing of TSA on the Office 

of Postsecondary Education Web pages.

The annual costs to the Federal Government are calculated as follows:

Professional Staff (300 hours x $44.00/hour)------------------ $13,200.00

Support Staff (100 hours x $13.00/hour)------------------------ $1,300.00

Computer time, Miscellaneous (Printing of documents

& mailing) $545.00

World Wide Web preparation and posting-------- $660.00

(One Professional Staff x 20 hours x $33.00/hour)

Total estimated cost to the Federal Government----------- $15,705.00

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).

Response: There are no program changes or adjustments – no additional information is 

requested from the respondents to submit to U.S. Department of Education than in prior 

years. 
7

ICRAS ICR ID and OMB Number: (1269.16) 1840-0595 Revised: 05/22/2013

RIN Number: Not Applicable

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. 

Response: Results are not intended for statistical use.

Letters to the Chief State School Officers designating Federal teacher shortage areas are

assured/insured, with copies distributed to several State contacts. Thereafter, a nationwide

list of teacher shortage areas is “ published” by the Department as well as posted on the

Department of Education Web site.

17. 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.

Response: The form to be cleared by OMB is an annual letter to CSSOs, 

requiring them to provide information on teacher shortage areas for the annual 

TSA Nationwide Report. The responses to each letter is a means (a tool) for the 

Department of Education to use to develop the annual TSA Report. The Annual 

TSA Report is the focus of the TSA initiative (rather than the annual “Dear CSSO”

letter) and is what is placed on the Department Web site annually, as noted in

Responses to Questions 10. and 16.

18. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

Response: The expiration date for OMB approval of the information 

collection will be displayed on the form.

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

Paperwork Reduction Act.

Response: There are no exceptions. 

Print Date: 6/13/2013