RACE TO THE TOP - EARLY LEARNING CHALLENGE PROGRAM

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

INTRODUCTION

Supporting America’s youngest learners and helping ensure that children, especially young children with 

high needs, such as those who are low-income, English learners, and children with disabilities or 

developmental delays, enter kindergarten ready to succeed in school and in life is a critical focus of the 

Obama Administration in Fiscal Year (FY) 2013. A robust body of research demonstrates that highquality early learning and development programs and services can improve young children’s health, 

social emotional and cognitive outcomes, enhance school readiness, and help close the wide school 

readiness gap that exists between children with high needs and their peers at the time they enter 

kindergarten. 

To address this educational gap, the Administration has identified, as high priorities, strengthening the 

quality of early learning and development programs and increasing access to high-quality early learning 

programs for all children, including those with high needs. This commitment to early education is 

reflected in the Race to the Top – Early Learning Challenge (RTT-ELC) program.

On May 25, 2011, Secretaries Duncan and Sebelius announced the RTT-ELC, a $500 million State-level 

grant competition held in FY 2011 and authorized under the American Recovery and Reinvestment Act 

of 2009 (ARRA), as amended by section 1832(b) of the Department of Defense and Full-Year Continuing 

Appropriations Act, 2011. The Departments administered this competition jointly. 

The purpose of the RTT-ELC program is to improve the quality of early learning and development and 

close the achievement gap for children with high needs. This program focuses on improving early 

learning and development for young children by supporting States' efforts to increase the number and 

percentage of low-income and disadvantaged children, in each age group of infants, toddlers, and 

preschoolers, who are enrolled in high-quality early learning and development programs; and designing 

and implementing an integrated system of high-quality early learning and development programs and 

services. 

At its core, RTT-ELC demonstrates a strong commitment by the Administration to stimulate a national 

effort to make sure all children enter kindergarten ready to succeed. Through the RTT-ELC, the 

Administration seeks to help close the achievement gap between children with high needs and their 

peers by supporting State efforts to build strong systems of early learning and development that provide 

increased access to high-quality programs for the children who need it most. The FY 2013 RTT-ELC 

competition represents an unprecedented opportunity for States to focus deeply on their early learning 

and development systems for children from birth through age five. It is an opportunity to build a more 

unified approach to supporting young children and their families--an approach that increases access to 

high-quality early learning and development programs and services, and helps ensure that children 

enter kindergarten with the skills, knowledge, and dispositions toward learning they need to be 

successful. 
The RTT-ELC grant program does not create new early learning and development programs, nor is it a 

vehicle for maintenance of the status quo. Rather, the RTT-ELC program will support States that 

demonstrate their commitment to integrating and aligning resources and policies across all of the State 

agencies that administer public funds related to early learning and development. It will further provide 

incentives to the States that commit to and implement high-quality early learning and development 

programs statewide. 

Many early learning and development programs and services co-exist within States, including Head 

Start/Early Head Start programs, the Child Care and Development Fund (CCDF) program (pursuant to the 

Child Care and Development Block Grant Act (42 U.S.C. 9858 et seq.)), State-funded preschool, programs 

authorized under section 619 of part B of the Individuals with Disabilities Education Act (IDEA) and part 

C of IDEA, and other State and locally supported programs. Each of these programs has its own funding 

stream and accompanying requirements, standards, expectations, policies, and procedures. Each also 

has its own unique strengths and makes unique contributions to young children and their families. For 

States, the challenges to be addressed by RTT-ELC are to sustain and build on the strengths of these 

programs, acknowledge and appreciate their differences, reduce inefficiency, improve quality, and 

ultimately deliver a coordinated set of services and experiences that support young children’s success in 

school and beyond.

The Departments made RTT-ELC awards in FY 2011 to nine States and an additional five States in FY 

2012. The Departments expect to make 6-8 additional awards in FY 2013 in a new competition, for an 

estimated total of 21 grantees. This collection will serve as the Annual Performance Report for all RTTELC grantees. The 2011 and 2012 grantees will report in February, 2014 and annually thereafter, and 

the 2013 grantees will submit their first report in February, 2015 and annually thereafter. 

A. JUSTIFICATION

1. Explain the circumstances making the collection of information necessary.

The Department of Education and the Department of Health and Human Services (Departments) are

requesting approval for a new collection, an Annual Performance Report for RTT-ELC grantees. The 

information submitted in the Annual Performance Report will be used to verify that grantees are making 

substantial progress toward the achievement of approved objectives. This grant awarded all funds up 

front, so the APR will not be used to determine continuation awards, but will be used to provide 

necessary performance information and data to program staff and to the public. Further, this APR form 

collects aggregate and quantifiable data needed to respond to the requirements of the Government 

Performance and Results Act (GPRA). 

Information is collected under the authority of Sections 14005 and 14006, Division A, of the American 

Recovery and Reinvestment Act of 2009, as amended by section 1832(b) of Division B of P.L. 112-10, the 

Department of Defense and Full-Year Continuing Appropriations Act, 2011, and the Department of 

Education Appropriations Act, 2012 (Title III of Division F of P.L. 112-74, the Consolidated Appropriations 

Act, 2012). (Attached is a copy of the authorizing statute.) 

2. Indicate how, by whom, and for what purpose the information is to be used.
The Department will use the data collected to evaluate a grantee’s accomplishments and to aid in 

compliance monitoring.

In addition, the annual performance reports are used to collect programmatic data for purposes of 

annual reporting; budget submissions to OMB; Congressional hearing testimonials; Congressional 

inquiries; performance measuring; and responding to inquiries from early childhood 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 techniques or forms of information 

technology, e.g. permitting electronic submission of responses, and the basis for the decision of 

adoption this means of collection. Also describe any consideration of using information technology to 

reduce burden.

The data being requested will allow the grantees to use computerized data systems to collect, retrieve, 

and report the requested information. The RTT-ELC program is currently using a web-based software 

application (GRADS 360) for program management and communication with Federal staff. A form will 

be developed for grantees to enter the data online and submit the entire report via the Internet. 

The data collected are summarized information on project participants and services and are low-level 

security risk. Nonetheless, the web site is secured to ensure the data are only seen by authorized 

individuals and are protected from external threats.

4. 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.

The information submitted in this report is unique to each respondent: therefore no duplication exists 

as far as can be determined. There is no other collection instrument available to collect the information 

the Department is required to assess to determine grantees’ program outcomes, as described in item 2, 

above.

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

method used to minimize burden.

The collection does not impact small entities because the only eligible grantees are States, and States 

are not 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.

Collection of information is annual. Collection of information on a less frequent basis is not feasible. 

These reports are used to determine if the grantee is making satisfactory progress in meeting the goals 

and objectives, as proposed in its initial application. Without this data collection, the Departments will 

be unable to respond to the GPRA requirements, monitor grantee performance, and 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 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-inaid, 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.

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 CFT 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 published a 60-and30-day notice in the Federal Register soliciting comments on the 

information collection.

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

contractors or grantees.

No payment or gifts to respondents will be made.

10. 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. Respondents will be informed that reports submitted under 

this collection will be made available to the public for transparency and accountability purposes. 

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. 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. 

The APR form does not include questions about sexual behavior and attitudes, religious beliefs, or other 

items that are commonly considered sensitive and private.

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

The Department estimates that each State would spend approximately 120 hours of staff time to 

complete the annual performance report. The total number of hours for the 21 States is an estimated 

2,520 hours. 

RespondentType Number of Respondents Hours Per Response Total Annual Hours 

State Educational 

Agency 21 120 2520

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

from the collection of information. 

The Department estimates that the hourly cost at State level will average $28.80 per person 

(approximately GS 12 equivalent) for a total of $72,576.00 (=120 hours X $28.80 X 21 States).

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. 

Program Staff Hours Amount

2 GS 12 x $28.80/hour 45 $2,592.00

2 GS 13 x $34.34/hour 30 $1,030.20

2 GS 14 x $40.58/hour 30 $2,434.80

1 GS 15 x $47.74/hour 30 $1,432.20

Total Federal Personnel Costs 120 $6,974.10

Printing (.05 ea. X 52 pages X 21 States) $54.60

Annual updates to web application, web-site hosting, help $150,000.00
desk and data processing (contractor costs) 

Grand Total $157,543.80

The annual cost to the Federal government is approximately $157,543.80 annually for the review 

efforts.

It is estimated that one full-time GS 15 (the Office of Early Learning’s Group Leader) will oversee the 

review efforts of the submitted APRs. An estimated seven Federal staff members from both 

Departments will review and comment on the submitted APRs (including the Group Leader). A total of 

135 hours is spent on this effort. 

The total estimated personnel and printing costs are $7,543.80.

There is an additional estimate of $150,000 in contractor costs, to provide a web-based reporting 

system that includes designing the form, pre-populating data, assisting grantees with data entry, and 

generating reports. 

15. Explain the reasons for any program changes or adjustments. 

This is a new data collection request; there are no adjustments with a program change increase of 2,520 

annual burden hours. The Race to the Top - Early Learning Challenge program was first authorized in 

2011 and made its first grant awards in December, 2011. The Departments collected performance data 

in February, 2013 from its first cohort of grantees without a collection approved by OMB, due to the

small number of grantees (9). However, in 2014 the program will require an approved APR to collect 

required performance data for 14 grantees, with an anticipated 21 grantees in 2015. 

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.

These reports will be made available to the public on www.ed.gov. Some of the information collected in 

this APR, such as performance data, will be analyzed and the results of those analyses will be shared on 

www.ed.gov. Reports will be collected each year in February and will be analyzed and posted between 

March and May of that year. No complex analytical techniques will be used. 

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. 

All data collection instruments will include the OMB expiration date.

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

paperwork Reduction Act Submissions” Form.

The Department is requesting an exception to the provision certifying a reduction in burden for small 

entities because the provision does not apply. The Secretary has certified in A.5 (above) that this 
proposed action will not have a significant economic impact on small entities because the only entities 

eligible to apply for grants are States and States are not small entities. Additionally, the provision for 

certifying the use of effective and efficient statistical survey methodology does not apply to this 

proposed action.