July 25, 2013

Supporting Statement for the Reporting Requirements for the Charter Schools 

Facilities Financing Demonstration/Credit Enhancement for Charter School 

Facilities Program

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.

The Credit Enhancement for Charter School Facilities Program and its virtually identical 

antecedent program, the Charter Schools Facilities Financing Demonstration Program, 

authorized as part of the reauthorization of the Elementary and Secondary Education Act,

to have a statutory mandate for an annual report (respectively, Section 5227 and Section 

10227). This reporting is a requirement in order to obtain or retain benefits according to 

section 5527 part b of the Elementary and Secondary Education Act of 1965. 

Statutory/Application Notice Requirements

All grantees must provide the following on an annual basis:

A. The grant performance summary page. This page provides key summary data related 

to the performance of the grant;

B. An evaluation by the grantee of the effectiveness of its use of Federal funds to 

leverage other funds. This evaluation must include a description of the activities used to 

assist charter schools in acquiring (by purchase, lease or donation) or constructing 

(including renovating, repairing, and altering) school facilities and a description of the 

characteristics of lenders and other financial institutions participating in the activities 

undertaken by the grantee. Furthermore, it must (1) include a statement about whether 

the grantee has sufficient resources from its grant to serve additional schools, (2) an 

approximate number of how many additional schools it can serve within 12 months, and 

(3) indicate the amount of grant funds available, including the amount of grant funds that 

are anticipated to be recycled within the next 12 months. In the event that the there have 

been any delinquencies or defaults, the grantee must identify the school(s) and remedies, 

and indicate both draws from and reimbursements to the reserve account. In the event 

that there has been a notice of probation, suspension, or revocation of a charter, the 

grantee must elaborate. In the event there was collaboration with another grantee to serve 

one or more charter schools, the grantee must indicate the names of the schools and the 

grantees;

C. A budget report including actual and projected expenditures. In addition, the report 

must include a brief narrative describing the uses of the actual expenditures;
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D. A timeline that includes specific schedules and accomplishments pertaining to the 

Grantee’s program. 

E. An IRS Form 990 (due 30 days after filing);

F. An audit report (including any opinion thereon); the OMB Circular A-133 audit; and 

audited financial statements, including (1) the management letter and any response(s); (2) 

schedules; and (3) auditor’s notes related to the specific activity for which the Grant 

money was awarded, (due 180 days following the end of the Grantee’s standard fiscal 

year);

G. The EXCEL spreadsheet. The EXCEL spreadsheet includes the Newly, Previously, 

and Leases workbook, the Budget workbook, and the Reconciliation workbook;

H. Bank or brokerage statement(s) for all reserve account investments and deposits as of 

the last day of the reporting period or as close to that date as possible. There is no need 

to submit statements for every month of the year.

Grantees that make loans or own school facilities

Furthermore, grantees that use their grants to credit-enhance loans that they (rather than a 

third party) make must provide copies of the term sheets for charter schools served under 

this grant as part of these reports. In addition, grantees that guarantee or insure leases of 

a building(s) that they own must submit a copy of the lease and the terms and conditions 

of the guarantee of the lease. 

Performance indicators

The performance indicators include:

A. The amount of funding grantees leverage for charter schools to acquire, construct, and 

renovate school facilities and

B. The number of charter schools served.

Unlike other discretionary grant programs administered by ED, this program is primarily

a financial program. These grantees draw down the entire amount of their grants after 

they sign a performance agreement acceptable to ED. All grantees must invest grant 

funds and use these monies to leverage non-Federal funds for the purchase, renovation, or 

construction of facilities by guaranteeing, insuring, reinsuring debt and leases. 

Monitoring these grants is critical to ensure that funds are properly invested, funds are 

properly spent or otherwise applied, and the grantees perform up to the level they

committed to in their performance agreements. Used properly, the funds should serve 

multiple charter schools and, over time, be recycled to help additional schools, thus 

extending these project grantee periods for approximately 30 years. 
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OMB clearance is requested for the entire annual report as the number of respondents 

exceeds 9.

To simplify reporting for the grantees, ED has divided the attached EXCEL spreadsheet 

into three workbooks: 1) Newly, Previously, and Leases; 2) Budget; and 3) 

Reconciliation. Each section is explained below. The information obtained in these 

annual reports would be used to monitor grantee performance.

1) Newly, Previously, and Leases: This section includes basic school identifiers that 

reveal what types of schools and students have been served with program funds. 

In addition, this section requests specific information regarding the financings, to 

assist ED in determining if the program provides better rates and returns than the 

schools would be otherwise able to obtain. Information provided in this section 

will also identify any defaults or other problems tied to repayments, and how the 

grantee has used grant funds to remedy such situations. This section requires 

details regarding the resulting facilities for each school (purchase, construction, 

and renovation details) and how such facility improvements and/or acquisitions 

may have enabled the schools to accommodate more students. Finally, while 

grantees primarily focus on guaranteeing and insuring debt, we also seek to 

capture uses of funds for the other three statutory purposes of the program: 

guaranteeing and insuring leases, facilitating lending, and facilitating bonding.

2) Budget: Since all of the grantee’s projects last for longer than the five years 

budgeted in the performance agreement, we seek to update these budgets, as well 

as to collect data on actual expenditures and earnings.

3) Reconciliation: This section would have grantees reconcile the balances for their 

reserve accounts. This grant program is unusual in that grantees may drawdown 

their entire grant without actually spending these funds. In addition, these grants 

can both increase in size through earnings on the grant funds and decrease in size 

due to defaults and other types of grant expenses. The reconciliation workbook

would help track these grant funds and decrease the ability of someone to misstate 

grant expenses or improperly use these funds. 

Lastly, grantees would include a summary page that would provide cursory quantitative 

information about the grantee’s performance. We require grantees to submit their most 

recent performance report as part of their grant application. The grant readers and ED’s 

evaluation office indicate that including this page would make it easier for them to judge 

the performance of the grantees.

Proposed Changes:

This is the third time the US Department of Education (ED) has changed the performance 

report for the Credit Enhancement for Charter School Facilities Grants program. ED is 

proposing to make one change to maximize the utility of the data collection. 
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 ED proposes to add four columns to the Excel under the Newly, Previously, and 

Leases workbook. These columns would collect student achievement data, based 

on prior year’s data, for Math and Reading, at the school level and at the State 

level. This information would not increase the burden of this report because the 

grantees collect student achievement data in their underwriting procedures and 

annually as part of their monitoring process. In addition to adding the columns, 

ED added instructions for completing these four columns in the “Reporting 

Instructions for the Charter Schools Facilities Demonstration Grants and Credit 

Enhancement for Charter school Facilities Grants.”

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 reports will be used to monitor grantees for compliance with their performance 

agreements and the statutory and regulatory requirements for the program. The reports 

will also be used to evaluate and improve the performance of the program. Furthermore, 

the reports will be used by the Secretary to report to Congress required under Section 

5227(b)(3)/10227(b)(3).

In addition, past performance reports must be added to the application package for the 

program (1855-007) since past performance is a factor under the selection criteria for 

previous grant recipients. 

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.

The Department plans to accept electronically submitted performance reports in Word 

and Excel. 

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.

The annual performance report is intended to serve a specific authorized purpose and is in 

keeping with statutory requirements. Without this data collection, the statutory

requirement cannot be met. 

The information supplied by the grantees is unique to this program and the particular 

grantee. Each grantee is required to submit an annual performance report that details its 

activities under the Credit Enhancement for Charter School Facilities Grants Program. 
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The information collected in the annual performance report is not collected by other data 

collections or sources. 

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

(Item 8b of IC Data Part 2), describe any methods used to minimize burden.

Small businesses are not impacted by this data collection.

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.

The Department needs the information to monitor and evaluate grantees. If no

information were collected, the Department would not be in compliance with the

authorizing statute and the application notice. In addition, the Department would not be

able to report on its GPRA performance indicators for the program. Data collection is

also critical in these grants to ensure that these multi-millionaire grants are appropriately

handled. 

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
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 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 that require the collection to be conducted in a 

manner inconsistent with the guidelines in 5 CFR 1320.5. 

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 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 Department held a meeting with grantees to discuss changes to the annual 

performance report in 2012. The Department asked for feedback on the current report 

and provided an opportunity for grantees to recommend additional changes. The 

grantees did not have recommendations or feedback. Also, a 60-and-30-day Federal 

Register Notice seeking public comments were published in the Federal Register. 

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

remuneration of contractors or grantees.

No gifts or payments will be made to respondents other than the award to the grant

recipient.

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

for the assurance in statute, regulation, or agency policy.

No assurance of confidentiality is provided.
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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 is no question of a sensitive nature in this collection of information.

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

statement should:

 Indicate the number of respondents, frequency of response, annual hour 

burden, and an explanation of how the burden was estimated. 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 

item 16 of IC Data Part 1.

 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.

We estimate respondent cost at an average of $30 per hour so that the average cost 

per annual report would be $30 x 25 hours = $750.

We expect that a total of 34 annual reports will be received from grantees. Total 

estimated cost: $25,500.

Estimated data burden for grants:

Annual reporting burden per response (preparing and submitting the annual report):

25 hours x 34 grants = 850 hours

Total Burden for Grants = 850 hours
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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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested : $ .00

There are no startup costs to respondents.

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 
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incurred without this collection of information. Agencies also may aggregate cost 

estimates from Items 12, 13, and 14 in a single table.

Estimated annualized Federal cost:

The salary of the staff that will be conducting the reviews is higher than previously

reported and therefore the estimated annualized Federal cost has increased. Currently,

the Department has one employee working on this program so this change is reflected in 

the below calculation. 

Program Personnel:

1 person @ $39.46 hr. x 600 hours = $23,640

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

Data Part 1 Form.

There is an adjustment increase of +150 hours, OII considers this an adjustment due to 

the increase in the number of grantees from 30 to 34. 

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 Secretary will use the results to report to Congress and in reporting data under the

Government Performance and Results Act.

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 expiration date will be displayed on the information collection.

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

Certification of Paperwork Reduction Act.

There is no exception to the certifications.

B. Statistical Methodology

This collection does not employ statistical methodology.