SUPPORTING STATEMENT

A. JUSTIFICATION

Q1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. 

Attached is a copy of the appropriate section of each statute and regulation mandating or 

authorizing the collection of information.

The U.S. Secretary of Education has proposed revising the final requirements for the School 

Improvement Grants (SIG) program, published in the Federal Register on October 28, 2010, 

authorized under section 1003(g) of title I of the Elementary and Secondary Education Act of 

1965, as amended (ESEA), to implement language in the Consolidated Appropriations Act, 

2014, that allows local educational agencies (LEAs) to implement additional interventions, 

provides flexibility for rural LEAs, and extends the grant period from three to five years. 

Additionally, the proposed requirements make changes that reflect lessons learned from four 

years of SIG implementation. 

These requirements contain information collection activities covered under the Paperwork 

Reduction Act (PRA) and cause revisions to the currently approved Office of Management and 

Budget (OMB) data collection under control 1810-0682. The activities that are currently 

approved by OMB consist of: (1) the state educational agency (SEAs’) preparation of 

applications to submit to the Department to apply for SIG funds and the SEAs’ posting of the 

LEAs’ applications on the SEAs’ Web sites; (2) the reporting of specific school-level data on the 

use of SIG funds and specific interventions implemented in LEAs receiving SIG funds that the 

Department currently collects through EDFacts (OMB Control 1875-0240); and (3) the 

application an LEA must submit to apply to its SEA for SIG funds. The following is a summary

of how the proposed requirements would change these activities and the effect they would have 

on the total annual approved burden. 

The Consolidated Appropriations Act, 2014 included changes to the SIG requirements that 

require changes to the current approved data collection. These changes are addressed in the 

NPRM and allow LEAs to implement additional interventions, provide flexibility for rural LEAs, 

and extend the grant period from three to five years. The amendments to the requirements also 

reflect lessons learned from four years of SIG implementation. Additionally, the amendments 

reflect the fact that, since the final requirements for the SIG program were published in 2010, 45 

SEAs received approval to implement ESEA flexibility, pursuant to which they no longer 

identify Title I schools for improvement, corrective action, or restructuring. To reflect this 

change, the amended requirements make priority schools, which are generally a State’s lowestachieving Title I schools, and focus schools, which are generally the schools within a State with 

the largest achievement gaps, eligible to receive SIG funds.

Under proposed requirement section II.B.1(b), each SEA may submit, as part of the required 

application it submits to the Department to receive SIG funds, one State-determined intervention 

model for review and approval by the Secretary. These proposed requirements would require an 

SEA to submit a proposed State-determined intervention model as part of its application, if a 

State choses to implement this model. 
2

The proposed requirements also make a number of clarifications to the reporting requirements. 

First, proposed requirement section III.A.3 eliminates the metric for “Truants” and replaces it 

with “Chronic absenteeism rates.” Second, proposed requirement III.A clarifies the correct 

source for each of the required metrics and removes references to the SFSF previously approved 

under OMB data collection 1810-0695. Finally, proposed requirements in section III.A.3 would 

require an SEA to report, with respect to schools receiving SIG awards, the number of schools 

implementing models with a modified element pursuant to proposed section I.B.6 and which 

models are being implemented in those schools. 

Regulatory and PRA Clearance Background

On December 10, 2009, the U.S. Department of Education (Department) published final 

requirements and a SEA application for the SIG program authorized under section 1003(g) of 

Title I of ESEA, as amended, and funded through the Department of Education Appropriations 

Act, 2009, and the American Recovery and Reinvestment Act of 2009 (ARRA) (FY 2009). On 

January 21, 2010, the Department published interim final requirements and a revised SEA 

application for FY 2009 SIG funds, which amended the final requirements and application issued 

in December.1 The Department issued an amended SEA application, containing technical 

changes from the application SEAs used to apply for FY 2009 funds, for FY 2010 SIG funds

provided through the FY 2010 appropriations act, also governed by section 1003(g) of the ESEA 

and the final requirements.

The final requirements defined the criteria that an SEA must use to award FY 2009 and FY 2010 

SIG funds to LEAs. In awarding these funds, an SEA must give priority to the LEAs with the 

lowest-achieving schools that demonstrate the greatest need for the funds and the strongest 

commitment to using the funds to provide adequate resources to their lowest-achieving schools 

that are eligible to receive services provided through SIG funds in order to raise substantially the 

achievement of the students attending those schools.

Those final requirements also included information collection activities covered under the PRA. 

The activities consisted of: (1) applications for an SEA to submit to the Department to apply for 

FY 2009, and FY 2010 SIG funds; (2) the reporting of specific school-level data on the use of 

SIG funds and specific interventions implemented in LEAs receiving SIG funds that the 

Department currently does not collect through EDFacts2; (3) the process for an LEA to apply to 

its SEA for SIG funds; and (4) the SEA’s posting its LEAs’ applications on the SEA’s website.

The Department received emergency approval of the information collection activities, including 

an application for FY 2009 funds, at the same time it issued the final requirements. OMB also 

approved a change to the collection at the time the Department issued the interim final 

requirements in January. These approvals permitted the SEA application process for FY 2009 

funds to begin so that students in the lowest-achieving schools start receiving the assistance they

need as soon as possible. 

 

1 Together, these requirements are referred to in this document as the “final requirements.”

2 The Department is proposing to collect this information through EDFacts. More information is provided in Q12.
3

The Department then requested regular approval of the information collection activities, 

including the amended SEA application for FY 2010 SIG funds, which was granted through 

September 30, 2016.

 

Q2. 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 is needed to successfully implement the SIG program. 

Q3. 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 of using 

information technology to reduce burden.

The information collections that involve SEAs providing information to the Department may be 

submitted electronically. An SEA may also have its LEAs submit their applications 

electronically to the SEA. 

Q4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use of the purposes described in Item 2 above.

There is no duplication in the collection. 

Q5. If the collection of information impacts small businesses or other small entities (Item 5 of 

OMB Form 83-I), describe any methods used to minimize burden.

The information collections in the final notice do not disproportionately add burden to small 

LEAs.

Q6. 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, the Department would not be able to continue to 

implement the SIG program in accordance with the President’s and Secretary of Education’s 

priorities. As a result, students attending the lowest-achieving schools would not receive 

services provided through SIG funds designed to substantially raise their achievement. 

Q7. Explain any special circumstance 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-
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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 

that 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 which 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.

This collection is consistent with 5 CFR 1320.5. 

Q8. 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 those 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 preclude 

consultation in a specific situation. These circumstances should be explained.

The Department has published a consecutive comment period with the proposed regulatory

requirement comment period under RIN 1810-AB22 Docket ID ED-2014-OESE-0079

published on September 8, 2014. 

Q9. Explain any decision to provide any payment or gift to respondents, other than 

renumeration of contractors or grantees.

No payments or gifts to respondents have been or will be made.

Q10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulations, or agency policy.

There is no assurance of confidentiality.

Q11. 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 
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private. This 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 are no questions of a sensitive nature.

Q12. 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 13 of OMB Form 83-I.

 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.

The final requirements include information collection activities for SEAs and LEAs. We 

provide a description of each activity and accompanying burden estimate in the following 

tables. The first table presents the estimate for SEAs and the second table presents the estimate 

for LEAs. 

The NPRM adds burden to the currently approved annual burden for SEAs. Under the reporting 

burden estimates, 52 SEAs will report SEA and LEA requirements for a total of 3,640 annual 

burden hours at a cost of $30 per hour totaling an annual cost of $109,200. The NPRM does not 

change the currently approved annual burden for LEAs. 
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State Educational Agency Estimate

SIG Activity Number of 

SEAs Hours/Activity Hours Cost/Hour Cost

Complete SEA

application 

(including requests 

for waivers) 52 100 5,200 $30 $156,000

Review and post 

LEA

applications 52 800 41,600 $30 $1,248,000

Reporting 52 70 3,640 $30 $109,200

Total 50,440 $30 $1,513,200

Local Educational Agency Estimate

SIG Activity Number of 

LEAs Hours/Activity Hours Cost/Hour Cost

Complete LEA 

application 3,050 60 183,000 $25 $4,575,000

Report data to SEA*

Total 183,000 $25 $4,575,000

* See the previous paragraph.

Q13. 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 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 
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keep records for the government, or (4) as part of customary and usual business or private 

practices.

There are no costs that (a) meet the criteria for inclusion under this item and (b) have not been 

addressed in either item #12 or #14.

Q14. 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 Federal costs related to the collections will primarily involve reviewing the SEA 

applications. We estimate a cost of $253,910. 

Q15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of 

the OMB Form 83-I.

The Consolidated Appropriations Act, 2014 included changes to the SIG requirements that 

require changes to the current approved data collection. These changes are addressed in the 

NPRM and allow LEAs to implement additional interventions, provide flexibility for rural 

LEAs, and extend the grant period from three to five years. The amendments to the 

requirements also reflect lessons learned from four years of SIG implementation. Additionally, 

the amendments reflect the fact that, since the final requirements for the SIG program were 

published in 2010, 45 SEAs received approval to implement ESEA flexibility, pursuant to 

which they no longer identify Title I schools for improvement, corrective action, or 

restructuring. To reflect this change, the amended requirements make priority schools, which 

are generally a State’s lowest-achieving Title I schools, and focus schools, which are generally 

the schools within a State with the largest achievement gaps, eligible to receive SIG funds. 

Under proposed requirement section II.B.1(b), each SEA may submit, as part of the required 

application it submits to the Department to receive SIG funds, one State-determined 

intervention model for review and approval by the Secretary. These proposed requirements 

would require an SEA to submit a proposed State-determined intervention model as part of its 

application, if a State choses to implement this model. The proposed requirements also make a 

number of clarifications to the reporting requirements. First, proposed requirement section 

III.A.3 eliminates the metric for “Truants” and replaces it with “Chronic absenteeism rates.” 

Second, proposed requirement III.A clarifies the correct source for each of the required metrics 

and removes references to the SFSF previously approved under OMB data collection 1810-

0695. Finally, proposed requirements in section III.A.3 would require an SEA to report, with 

respect to schools receiving SIG awards, the number of schools implementing models with a 

modified element pursuant to proposed section I.B.6 and which models are being implemented 

in those schools. There is a program change increase of +3640 annual burden hours due to new 

statutory requirements..

Q16. 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.
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There are no plans to publish the results of this data collection.

Q17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

No request is being made to not display the expiration date for OMB approval of the 

information collection.

Q18. Explain each exception to the certification statement identified in Item 20, "Certification 

for Paperwork Reduction Act Submissions," of OMB Form 83-I.

There are no exceptions to the referenced certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS 

This information collection does not employ statistical methods.