1

EDICS Tracking and OMB Number: (XXXX) 1840-0616 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.

Information collection for the Centers for International Business Education (CIBE) program is necessary

for institutions of higher education to receive grants. The last approval for the collection of information 

for this program (OMB number 1840-0616) was discontinued on May 31, 2012 to allow for revisions to 

the collection due to new GPRA measures. We request a reinstatement with change to allow the 

International and Foreign Language Education office (IFLE) to invite applications under the CIBE 

program in spring 2014, conduct peer reviews of grant applications, select grant recipients, and make new 

awards within established grant schedules in FY 2014. 

Information Collection CFDA 

No.

Date 

Respondents 

Submit

Applications 

Information 

Collection Required 

 for

Fiscal Year Awards 

(New)

Centers for International Business 

Education

84.220 06/2014 FY 2014

The CIBE program is authorized under part B, Title	VI	of	the	Higher	Education	Act	of	1965	(HEA),	as	

amended. Other legislation and regulations relevant to this information collection include the 

Government Performance and Results Act; section 427 of the General Education Provisions Act; the 

Government Paperwork Elimination Act; and the Education Department General Administrative 

Regulations.

This information collection is being submitted under the Streamlined Clearance Process for Discretionary

Grant Information Collections. 

This information collection is also associated with a notice of proposed priorities.

 

1

Please limit pasted text to no longer than 3 paragraphs.
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EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

The CIBE program provides federal assistance to Centers for International Business Education that serve 

as national centers for the teaching of improved international business techniques and develop regional 

resources to meet the international training needs of local businesses.

The authorizing legislation is included on pages 14-19 of the application packages attached to this 

supporting statement. There are no program specific regulations for this program.

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.	

Eligible institutions of higher education use the information to develop and submit grant applications to 

the Department of Education (ED). After grant applications are submitted, ED determines the budgetary

and human resources it needs to conduct competitions. Expert review panels use the information to 

identify high-quality applicants. ED program officials consider the feedback from the expert review 

panels, in conjunction with the program’s legislative purposes, when making funding recommendations. 

ED also uses the information collection to develop monitoring plans, to inform strategic planning, and to 

align program assessment standards with Department performance goals and initiatives. 

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 information collection requires applicants for grants under the CIBE program to submit applications 

electronically using Grants.gov. 

Program competitions are held every four years. The CIBE program will utilize the Grants.gov system for 

the second time in FY 2014. During competitions prior to FY 2010, the CIBE program used the 

Department’s e-Grants system for submission of applications. 

Regarding the use of other forms of information technology, we use the Department’s Web site to inform 

prospective applicants about the program’s funding opportunities and deadline dates. Application 

packages are posted on the Web site after the competition is closed, making access to them more effective 

and efficient. Additionally, we post Frequently-Asked Questions about these programs on our Web page, 

which makes technical assistance more immediate. As a technical assistance tool, we post abstracts of 

currently funded projects on ED’s Web site to help prospective applicants better understand the kinds of 

activities and projects the program supports. 

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.

No other information collections duplicate what is being requested under this collection. Likewise, there 

is no duplication elsewhere in the Federal government of IFLE program planning and oversight activities 

associated with this program. 
3

EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

The legislative authority covered by this information collection is unique to the program. Because of 

these inherently unique programmatic characteristics, no other similar programs exist in the Department, 

and no similar programs exist in other Federal agencies.

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.

The collection of information does not impact 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	frequently,	as	well	as	any	technical	or	legal	obstacles	to	

reducing	burden.

If the collection is not conducted, ED cannot meet its grant making responsibilities, including the 

publication of notices inviting applications, providing technical assistance to new respondents, conducting 

peer reviews of grant applications, transmitting slates with funding recommendations to program officials 

for approval, and making grant awards. 

The Department needs to make grant applications available to its constituencies to give eligible applicants 

at least 30 days to develop and submit applications by the dates specified in Item 1, and to enable IFLE to 

make new fiscal year grant awards in a timely manner. 

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;
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EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

 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 circumstances that would cause this information collection to be conducted in this manner.

 

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.

As	required	by	5	CFR	1320.8(d),	the	Department	will	publish	a	notice	in	the	Federal	Register	to	

solicit	public	comments	on	this	information	collection.	The	notice	will	be	published	jointly	with	the	

FY	2014	Notice	of	Proposed	Priorities	for	this	program,	and	the	comment	periods	for	the	

information	collection	and	the	proposed	priorities	will	run	concurrently.

The	International	Foreign	Education	Programs	Service	(IFLE)	hosted	a	Technical	Assistance	

Workshop	in	September,	2013	for	prospective	applicants.		During	that	time	we	met	with	various	

representatives	from	private	and	public	institutions	of	higher	education	to	discuss	the	CIBE	

selection	criteria,	program	instructions,	and	forms.		Representatives	included	project	directors,	

foreign	language	pedagogy	experts,	and	data	analysts	who	are	responsible	for	gathering	the	data	

required	for	a	CIBE grant	application.		Workshop	attendees	also	included	postsecondary	faculty	and	

administrators	who	are	recipients	of	the	training	materials	and	instructional	services	that	the	CIBE

program	provides.	

On a regular basis, we hold informal discussions with various constituents and potential respondents who 

have completed grant applications under this program to ascertain whether the instructions and forms are 

clear and applicant-friendly. These include project directors, deans, chairs of academic departments, 

language and area and international studies professors, fiscal representatives at institutions, and 
5

EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

management analysts who are responsible for gathering the data needed to respond to the program’s 

selection criteria. 

Our day-to-day technical assistance, project monitoring, and site visits are the primary mechanisms we use 

to answer specific questions about the grant application instructions and to gauge whether or not 

application materials are useful and do not impose an unrealistic burden on respondents. Day-to-day

technical assistance includes phone conversations, e-mails, faxes, and office visits. We also conduct 

technical assistance workshops at various conferences throughout the year. In sum, these processes 

collectively inform IFLE about the viability of the application materials we use for our programs. The 

professionals, administrators, and organizations cited above do not have adverse comments about the 

information being requested or about the time it takes to complete a grant application under this program. 

 

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

remuneration	of	contractors	or	grantees	with	meaningful	justification.

Other than remuneration of grantees via grant awards, there are no payments or gifts 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	IC	Data	Form.	A	confidentiality	statement	

with	a	legal	citation	that	authorizes	the	pledge	of	confidentiality	should	be	provided.2 If	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.

Assurances of confidentiality related to this information collection are covered under the Privacy Act. 

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 asked. 

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

should:

 

2

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)
6

EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

 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	

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

14.

This request for approval covers information collections (application forms). Using the 

communication mechanisms described in Item 8, we contacted a sampling of respondents to get their 

input on the time and resources they require to complete grant applications. The table below presents 

the burden hour and cost for each form separately, as instructed. 

The data in the table are estimates of the time it takes for respondents to complete official forms, 

develop the application narrative and budget, and submit completed applications through the 

Grants.gov system that responds to individual selection criteria.

Estimate of Annualized Burden Hours and Cost to Respondents 

Information Collection

(Grant Application)

Number of 

Respondents

Hours 

per 

Response 

Total 

Hours

Frequency 

of 

Response 

Wage

per Hour

Annualized Cost 

for the 

Information 

Collection

Centers for International 

Business Education Program 

(CFDA 84.220)

50 150 7,500 Every 4

years

$85 $159,375
7

EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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.	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) :	

____________________

The program in this information collection does not have costs that meet the criteria for inclusion in Item 

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.

The annualized cost to the Federal government in the table below includes costs related to primary

operational and programmatic tasks necessitated by this collection of information. This information 

collection covers the CIBE program and requires the resources of one program officer, one branch chief to 
8

EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

provide oversight, the occasional use of one administrative assistant, and external peer review panels to 

conduct the tasks. 

Estimates of Annualized Cost to the Federal Government

Operational or Programmatic Task Wage 

per Hour

Staff 

Resources

Total

Hours

Cost to 

Federal 

Government

Gather data and develop OMB justification statement $50 1 20 $1,000

Develop application forms and instructions $50 1 90 $4,500

Develop Notice Inviting Applications $50 1 30 $1,500

Enter approved collection into ICRAS $40 1 1 $40

Enter application and forms into Grants.gov 

Application module for respondents to access 

$40 1 1 $40

Post application on the Department’s website $40 1 1 $40

Establish reader panels in Field Reader System to 

evaluate 50 e-Applications 

$40 1 15 $600

Send conflict of interest forms to reviewers; process 

certifications; mail Field Reader System manuals to 

reviewers

$40 1 15 $600

Conduct conference calls; monitor panels via e-mails; 

read reviewers’ comments in G5

$50 2 60 $6,000

Download and print 50 applications and 200 technical 

review forms 

$40 1 70 $2,800

Compensate 16 reviewers after certifying satisfactory 

completion of peer review to evaluate applications 

$1000 flat 

rate 

 16 60 $16,000

Review applications in funding range; prepare slate 

memo and attachments for review by Branch Chief 

$50 1 100 $5,000

ED Program officials approve slate $150 3 3 $1,350

Commit grants in G5 $50 1 1 $50

Team Leader obligates grants in G5 $75 1 1 $75

Review revised budgets; mail grant award documents $50 1 10 $500

Document monitoring activities weekly for all 

projects in compliance with OPE standards

$50 1 800 $40,000

TOTAL 1278 $80,095

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.).	
9

EDICS Tracking and OMB Number: (XXXX) 1840-0616 Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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).

This	is	a	reinstatement	of	a	previously	approved	collection.	As	required	by	GPRA,	ED	has	developed	

a	strategic	plan	that	reflects	its	organizational	priorities	and	also	integrates	IFLE’s	mission	and	

program	authorities.	ED’s	stated	goal	for	IFLE	is	"to	meet	the	nation's	security	and	economic	needs	

through	the	development	and	maintenance	of	a	national	capacity	in	foreign	languages,	and	area	and	

international	studies.”	In	FY	2013	the	Department	revised	its	GPRA	measures	to	better	target	

performance	and	evaluation	measures.		The	changes	reflected	in	the	application	document	

represent an	effort	to	assist	applicants	with	providing	data for	collection	to	respond	to	these	new	

GPRA	measures.	Program-specific	guidance	has	been	provided	in	the	collection	on	preparing	

evaluation	plans,	proposing	project-specific	measures,	and	reporting	data	to	respond	to	program	

GPRA	measures	for	use	in	the	FY	2014	competition	cycle	and	beyond.	It	will	take	applicants	

additional	time	to	review	this	new	guidance,	and	to	develop	more	amplified	evaluation	plans.	The	

application	also	asks	new	applicants	to	include	project-specific	measures	in	their	grant	proposal,

which	is	a	new	requirement.

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.

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

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.

We will display the expiration date.

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

Paperwork	Reduction	Act.

There are no exceptions to the certification statement.