1 **SUPPOR TING ST**  **AT EMENT**  **FOR P APER**  **WORK REDUCTION ACT SUBMISSION**  **(03287) 1840 -**  **0793 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 section. Please limit pasted text to no longer than 3 pages. Specify the revi ew 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. Consistent with the provisions of Title VII, Part B of the Higher Education Act of 1965, as amended, the Fund for the Improvement of Postsecondary Education (FIPSE) works to improve postsecondary education through grants to postsecondary educational instit utions and agencies. Such grants are awarded to non - profit organizations on the basis of competitively reviewed applications submitted to FIPSE under its Comprehensive and Special Focus Competition Program grant com

petitions. The Department of Education is requesting permission to conduct combined data collection for the Comprehensive Program (84. 11 6 B ), four (4) Special Focus Programs: European Union/United States of Am erica Cooperation Program in Higher Education and Vocational Education and Training (EU
- U.S. Atlantis Program), the Program for North American Mobility in Higher Education (North American Program), the U.S.
- Brazil Higher Education Consortia Program (U.S.
- Brazil Program), and the U.S.
- Russia Program (new program funded since Fiscal Year ( FY ) 2007). The r egulations governing these program s are contained in 34 CFR Part 75 (Education Department General Administrative Regulations). The Com prehensive Program has been funding improvements in postsecondary education annually since its authorizati on in 1973. FIPSE has not received an appropriation from Congress to support the Com prehensive or International Partnership programs since 2011
. However, FIPSE remains in the Federal Budget and may have future competitions to administer and therefore all reports are necessary. In addition, t

he projects funded in FY 2010 were funded for three and2

four years and will continue into 2014. Thus these grantees will not file their final reports until the end of 2014. 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. **Comprehensive and International Project Forms ( annual and final**  **reports for**  **84.116B, J, M, N, and S):** The annual and final performance report s are necessary to ensure that the information and data to be collected will result in a balanced and effective assessment of the student exchanges and curricular developments of the Com prehensive and four international programs . The U.S. Department of Education standard forms for annual and final performance reports ask grantees to provide information that is not suited to consortium
- based projects. The FIPSE form s include requests for performance information, a report narrative, a student mo bility data sheet, a final budget summary, and a project description. We requir e the grantee to write an essay describing the key accomplishments and challenges of the project . T he information to be collected in the forms reflect s the focus of the project activities much more accurately and includes a required evaluation report
. FIPSE places great emphasis on the collection of information from performance reports as a means to assure the quality of program management and show progress toward meeting its performance goals
. **Congressionally -**  **directed Grant**  **forms ( final report**  **for 84.116Z )**  **:** Results of the final p erformance report will be used to ensure that grant expenditures were used toward the accomplishment of a specified congressional purpose stated in the Appropriations Act. The reports are collected via the FIPSE database to strengthen FIPSE’s methods of internal controls for monitoring grant expenditures and enhancing transparency of project activities. It will also serve as a safeguard and check
- and
- balance system against possible fraudulent activity. Since these are Congressionally
- directed grants and therefore noncompetitive, FIPSE staff need to closely monitor these projec ts to assure that tax payer monies are spent according to Federal regulation s . The dat a provide d in the final performance reports will ascertain if grant recipients have expended funds for the Congressionally
- directed purpose specified in the conference report, H. Rept. 111
- 366, pages 106 6
- 1072 or if activities and expenditures were in compliance with discretionary grant regulations. 3. Describe wh ether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection3

techniques or forms of information technology, e.g. permitting electronic submission of responses, and the bas is for the decision of adopting this means of collection. Also describe any consideration of using information technology to reduce burden. T he collection of information is designed for Web
- based submission of all the information requested. Grantees wil l be able to use the FIPSE database ( www.fipsedatabase.ed.gov ) to submit final and annual performance information on their grants. The Comprehensive Program and the four (4) international program s will use the same form s for the annual and final performance report , with the exception of an added section for the international programs that collects data on students studying abroad for the Department of State’s International Agency Working Group (IAWG)
. The Congressionally
- directed grants have a slightly different format due to the nature of Congressionally
- directed grants. The data collected in the FIPSE database enables the program officers to conduct program evaluation of FIPSE’s program s to provide outcom es and outputs as well as im prove the program management of the programs. 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. FIPSE staff has made every effort to ensure that there is no duplication of data acquisition. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity ma y 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 bus inesses or other small entities.4

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. According to the Government Performance and Results Act of 1993 (GPRA), FIPSE grant competitions are required by law to collect information regarding program and project effectiveness. 7. Explain any special circumstances that would cause an information collection to be cond

ucted 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 respondent

s 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 confidentiali ty that is not supported by authority established in statute or regulation, that is not supported by disclosure and da ta 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 th a t it has instituted procedures to protect the information’s confidentiality to the extent permitted b y law. No special circumstances apply.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 th e 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. Each year FIPSE staff evaluates the effectiveness of grants and related processes, including data collection, through regular telephone and e
- ma il contacts with project directors, an annual meeting of the project directors in each program, and annual performance reports submitted by the grantees. Information gathered through such means is focused on objectives un ique to individual projects. The FIPSE database greatly facilitate s total program evaluation objectives such as the effectiveness of the consortia format or student learning outcomes that are common to a cohort of projects both within and across the four programs in areas such as engineering or business and if applicable any Congressionally
- directed grants
. 9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. ED does not provide any payment or gift 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 co llected, 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 as6

indicated on the ICRAS’ Part 2 IC form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 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). If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to c onfidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data. No assurance of confidentiality is provided to respondents
. 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. This program does not include information of a sensitive nature. 12. Provide estimates of th e 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 condu ct 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 acti vity, 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.7

-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 not be included in Item 14. **ANNUAL REPORT Form for 84.116B**  Num ber of respondents 1 00 Frequency of response Annual Hour burden 1 7 Total burden 1700 Total est. cost to respondents $ 85,000 **FINAL REPORT Form for 84.116B,J,M,N or S**  **Form for 84.116Z** Num ber of respondents 100 147 Frequency of response One time One time Hour burden 17 10 Total burden 1,700 1470 Total est. cost to respondents $ 85,000 $ 73,500

 Annual Grand Total for three ( 3 ) forms: 4,870 hours  Annual Grand Total estimated cost to respondents for three ( 3 ) forms: $ 243,500 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 descriptions8

of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipmen t, 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 te sting 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 analy sis 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 compl iance 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/St artup Cost : $ .00 Total Annual Costs (O&

M) : .00

____________________ Total Annualized Costs Requ ested : There are no annualized costs requested. 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 withou t this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. 5% of three staff salaries $ 13,500 30% of overhead for support $ 3 , 0009 Contractor personnel costs $ 60 ,000 Total cost of Contract and Department of Education staff/overhead.....$ 76,500 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83
-I. This is a currently active collection. The reduction in burden hours resulted from decreases in the number of respondents for all the programs. S ince 2010, we have not held new competitions for the Comprehensive or Special Focus Programs thus reducing the number of respondents
. Moreover, we are eliminating the annual report for the C ongressionally
- directed grants since it is unlikely that there will be C ongressionally
- directed grants in the future. We made fewer C ongressionally
directed grants in 2010

– only 147

– thus reducing the num ber of respondents. The num ber hours for completing the report have remained the same
. The burden for the FIPSE Comprehensive Annual Report increased because the num ber of hours per respondent was raised from 8 to 1 7 to better reflect report completion time. 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 sched ule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. The findings and results obtained from this collection will be based on self
reported information and on inferences and conclusions drawn across all of the funded projects. Selected information is available on the FIPSE web site: http://www2. ed.gov/about/offices/list/ope/fipse/index.html
. 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 for OMB a pproval of the collection. 18. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83
- I.10

We are not requesting any exceptions.