**Upward Bound Program s: Upward Bound and**  **U pward Bound Math and Science**  **Request for Approval under the Paperwork Reduction Act Supporting Statement for the New Annual Performance Report Form** 

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 auth orizing the collection of information. The Department of Education ( Department) is requesting approval of a new Upward Bound (UB) Annual Performance Report (APR) form to collect annual performance report data from projects funded by UB program grants . This APR reflects new UB program regulations enacted on Oct ober 26, 2010. The new regulations were necessitated b y changes to the UB program in the Higher Education Opportunity

Act (HEOA) of 2008. FY 2012

- 2013 is the first year of a five year grant cycle during which UB projects ar e required to adhere to the new regulations. The UB program provide s Federal financial assistance in the form of discretionary

grants to : (a) institutions of higher education ; (b) public and private age ncies and organizations including community

- based organizations with experience in serving disadvantaged youth ; (c) secondary schools; and (d) combinations of such institutions, agencies and organizations

. The specific goal s of UB are to provide fundamental support to participants in their pr eparation for college entrance. The program provides opportunities for participants to succeed in their precollege performance and ultimatel y in their h igher education pursuits. UB serv es high sc hool students from low

- income families and high school students from families in which neither parent holds a bachelor's degree. The goal of UB is to increase the rate at which participants complete secondary education and enroll in and graduate from inst itutions of postsecondary education. The information that grantees submit in the APR allows the Department to annually assess each grantee's progress in meeting their project's approved goals and objectives. The APR data are compared with the projects’ ap proved objectives to determine the project s’ accomplishments, to make decisions regarding whether funding should be continued, and to award "prior experience" (PE) points. The regulations for this program provide for awarding up to 15 points for prior exp erience (34 CR 64 5.3 2). During a competition for new grant awards, the PE points are added to the average of the field reader scores to arrive at a total score for each application. Funding recommendations and decisions are primarily based on the rank order of applications on the slate; therefore, assessment of PE points, base d on data submitted in the APR , is a crucial part of the overall application process.2 Further, this performance report form collects aggregate and quantifiable data needed to respond to the requirements of the Government Performance and Results Act (GPRA) . In the Department of Education’s Fiscal Year 2010 Annual Performance Plan, the overall objective for the UB Program is to : “Increase the percentage of low

- income, first generation students who enter and succeed in a program of postsecondary education.” The Department collects information from UB grantees under the authority of Title IV, Part A, Subpart 2, Chapter 1, Section s 402 C of the Higher Education Act of 1965, as amended, the program regulations in 34 CFR 64 5 , and 34 CFR Sections 74.51, 75.720 and 75. 732 of the Education Department General Adm inistrative Regulations (EDGAR)

. [ A cop y of the authorizing statute, as amended in 2008 as the Higher Education Opportunity Act , which is the basis for the current program regulations, is also attached. ] 2. In dicate 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 to (a) evaluate projects' accomplishments ; (b) determine the number of PE points to be awarded to current grantees ; and (c) aid in compliance monitoring ( i.e ., to determine whether grantees are in compliance with the selection requirements for project participants )

. [34.CFR 645.3] In addition, the Department uses the APRs to produce program

- level data for annual reporting, budget submissions to OMB, and Congressional hearings , testimonials and inquiries , and to respond to inquiries from higher education interest groups and the general public. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniqu es 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 data collectio n method allows the grantees to use computerized data s ystems to collect, retrieve, and report the requested information. A Web

- based software application has been developed for grantees to enter the data online and submit the entir e report via the Intern et
. The UB project s have been submitting the annual performance report via the Internet since 2001

. The data collected are in the aggregate form at the program level , not data on individual participants; thus the reports are a low

- level security risk. Nonetheless, the Web site is secured to ensure that the data are seen only by authorized3 individuals and are protected from network hackers. Further, online data edits are in place to ensure the accuracy and integrity

of the data submitted. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information already available cannot be used or modified for use for the purposes described in Item 2 above. T he information grantees submit in their performance reports is unique to each project and is not collected elsewhere ; therefore , no duplication exists. N o other collection instrument is available to collect the information the Department is required to assess to determine grantees’ prior experience points and program outcomes, as described in item 2, above. The data collected in the APR are fundamental to th is program. 5. If the collection of information impacts small busi nesses or other small entities , describe an y methods used to minimize burden. This information collection does not affect small businesses or other small entities. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. The collection of performance reports is required annually . Collection of information on a less frequent basis is not feasible. These reports are used to determin e if the grantee is making satisfactory progress in meeting the goals and objectives proposed in its initial grant application

. Inaddition, the information is needed to award PE points to grantees. Without this data collection, the Department would not have the data to assess the PE provision of the authorizing statute, respond to the GPRA and other program performance and efficiency measures, or develop improved policies for program administration. 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 quarterl y;
 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 th an three ye ars;4  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 impede s 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 inform ation’s confidentiality to the extent permitted by law. With one exception, no information will be collected in the manner covered under any of the special circumstances outlined. The exception is that respondents are required to retain participant record s for more than three years as required under 34 CFR 74.53(b). In order to assess the impact of the program services on participating students’ academic progress , and in anticipation of the new outcome measure for UB which occurred as a result of the HEOA , grantees should track the academic progress of all prior

- year participants , beginning with the 2008 high school graduating cohort, until postsecondary completion. 8. As applicable, state that the Department ha s published the 60

- day and 30

- day Federal Regis ter notices as requi red 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 burde n. Describe efforts to consult with persons outside the agency to obtain their views on the availability

of data, frequency

of collection, the clarit y of instruction and record keeping, disclo sure, or reporting format (if an y) , 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 ye ars

– 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. Department staff members have attended a number of state, regional, and national meetings at which the Department solicited informal views and comments on reporting requirements from grantees and other interested persons. A separate 60

-5 day Federal Register notice followed b y a 30

- day Federal Regis ter notice will be published to solicit public comment on the new APR form

. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees. The Department wi ll not provide pay ment or gifts to respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy

. No assurances of confidentiality are provided to the respondents

. 11. Provide additional justification for an y 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 nec essary , 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. The performance report form does not include questions about sexual behavior and attitudes, religious beliefs, or other matters that are commonly considered sensitive and private. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affecte d public ty

pe (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 ty pe: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obta in 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 widel y 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.

 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate6 categories. The cost of contracting o ut or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14. Estimated burden hours for this collection of information are 1 6 , 864 hours. We estimate approximately 992 respondents

. The performance reports are submitted annually

. Number of Respondents Estimated

Preparation Time , per respondent Total estimated

burden hours Public Sector 737 17 12,529 Private Sector 255 17 4,335 **Total estimated burden hours**  **992 17**  **16,864**
( Estimated burden: 16,864 hours. Total number of hours (preparation time) multiplied by the total number of respondents equals estimated burden hours). Preparation time includes 1 5 hours for professional staff to gather the information using computerized technology

and 2 hours for clerical staff to enter the data into the Web

- based form. Professional staff ( 992 respondents X 15 hours X $35 per hour) $ 520,800 Clerical staff ( 992 clerical staff members X 2 h ours X $18 p er hour) $ 35,712 Total estimated cost to all respondents $ 556,512 Note : As many of the respondents are project staff whose salaries are largely financed with Federal grant funds, the Department believes that the actual cost to respondents is lower than those indicated above but cannot provide an accurate estimate at this time. 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 s ys tem 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 and7 software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaini ng record storage facilities.

 If cost estimates are expected to vary widel y, 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 cos t 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 anal ys is 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 requireme nts 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. There are no other costs to the respondents asso ciated with this information collection

. Grantees are required b y program regulations to collect and maintain this information. The costs to transmit the data electronicall y via the Web are customary and usual business practices. 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 an y other exp ense 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 largest portion of the Government's cost is borne directl y b y the Department of Edu cation in designing the report form, securing clearance of the form, and collecting, aggregating, and disseminating the information. Annual contract cost for development of APR Web application, Web

- based data collection, Help Desk support, data processing, and grantee PE reports. $102,192
Analy ses of data and preparation of national statistical reports. $155,000 Professional staff to update report form and prepare clearance package c learing performance report form: $55 per hour X 120 hours Overhead (est. at 50%): 120 times $27.50 $9,9008 Professional staff to review and edit reports for dissemination $55 per hour X 160 hours Overhead (est. at 50%): 160 times $27.50 $13,200
Clerical staff to type, route, and cop y report form: $ 19 per hour X 15 hours Overhead costs (est.at 50%) 15 times 9.5 $42 8

Other Department staff to review and approve the request: $55 per hour X 10 hours Overhead costs (est. at 50%) 10 times 27.50 $825 OMB review (estimated): $55 per hour X 8 hours Overhead costs (est. at 50%) 8 times 27.50 $660
TOTAL FEDERAL COST $282,20 5
15. Explain the reasons for an y program changes or adjustments. In previous ye ars, the same APR was used for three of the TRIO programs (Upward Bound, Upward Bound Math and Science and Veterans Upward Bound) because of the similarities in the data collected for each program. However, s tatutory changes and subsequent new regulations resulted in significant di fferences in the performance measures for the UB and UBMS p rogram s . Specificall y, grantees must track the academic progress of UB and UBMS participants through postsecondary comple tion , and this will increase the reporting burden b y six hours for each grantee. Therefore, this form will be used to collect data on UB and UBMS participants . Additionally , the final regulatory amendments to recordkeeping requirements require that UB an d UBMS grantee s document the services a student who is served b y more than one TRIO or other federally funded program is receiving from ano ther program during the project ye ar. This change will result in an increase of two burden hours. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address an y complex anal yt ical 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. Collected information will be anal yz ed annuall y to determine if each grantee is meeting its approved goals and objectives and to award PE points. Performance me asures and efficiency

measures for UB , based on data conveyed in grantees' APRs , are disseminated in the Department's Annual Program Performance Plan. In addition , the Department 's Web site provides data on performance and efficiency measures , beginning w ith the 200 7

– 0 8 performance period, at the grantee level ; this more detailed reporting has been made possible due to9 improvements in accuracy result ing from incorporating the standard objectives into the report form. 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 form and the Web site will display the expiration date for OMB's 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. B. Collections of Information Employing Statistical Methods This collection does n ot employ statistical methods.