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SUPPORTING STATEMENT

FOR PAPERWORK 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 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.

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 institutions 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 competitions. The Department of Education is requesting 

permission to conduct combined data collection for the Comprehensive Program 

(84.116B), four (4) Special Focus Programs: European Union/United States of 

America 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 regulations governing these 

programs are contained in 34 CFR Part 75 (Education Department General 

Administrative Regulations). 

The Comprehensive Program has been funding improvements in postsecondary 

education annually since its authorization in 1973. FIPSE has not received an 

appropriation from Congress to support the Comprehensive 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, the projects funded in FY 2010 were funded for three and 
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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 reports 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 

Comprehensive 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 

forms include requests for performance information, a report narrative, a student 

mobility data sheet, a final budget summary, and a project description. We require

the grantee to write an essay describing the key accomplishments and challenges of 

the project. The information to be collected in the forms reflects 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 performance 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 projects to assure that tax payer monies 

are spent according to Federal regulations. The data provided 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 1066-1072 or if activities and expenditures were in compliance with 

discretionary grant regulations. 

3. Describe whether, and to what extent, the collection of information involves the 

use of automated, electronic, mechanical, or other technological collection 
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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 collection of information is designed for Web-based submission of all the 

information requested. Grantees will 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 

programs will use the same forms 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 programs to provide outcomes and outputs as well 

as improve 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 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.
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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 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;

-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.

No special circumstances apply.
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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 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.

Each year FIPSE staff evaluates the effectiveness of grants and related processes, 

including data collection, through regular telephone and e-mail 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 unique to individual projects. The 

FIPSE database greatly facilitates 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 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 
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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 confidentiality. 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 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.
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-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

Number of respondents 100

Frequency of response Annual

Hour burden 17

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

Number 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 descriptions 
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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 keep records for the 

government, or (4) as part of customary and usual business or private 

practices.

Total Annualized Capital/Startup Cost: $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested :

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 without 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 $ 3,000
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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. Since 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 Congressionally-directed grants since it is unlikely that there will be 

Congressionally-directed grants in the future. We made fewer Congressionallydirected grants in 2010 – only 147 – thus reducing the number of respondents. The 

number hours for completing the report have remained the same. The burden for 

the FIPSE Comprehensive Annual Report increased because the number of hours 

per respondent was raised from 8 to 17 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 schedule 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 selfreported 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 approval 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.
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We are not requesting any exceptions.