1

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- 0023 Revised: 1/ 17 /201 4 **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Charter School Authorizer Annual Update administered by the National Charter School Resource Center**  

### 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**  **, 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.** The U.S. Department of Education (ED) has as one of its important policy goals expanding the number of high

- quality public school choice options. Specificall y, according to Part B section 5201 of the Elementary

and Secondary

Education Act, two of the established purposes of the Charter School Program office are: evaluating the effects of charter schools, including the effects on students, student academic achievement, staff and parents, and expanding the number of high

quality charter schools available to students across the nation. Charter school authorization is at the very crux of any

efforts to expand and ensure high

- quality public school choice options through public charter schools bec ause charter school authorizers are the public entities primarily responsible for: initial charter authorizations, on

- going monitoring and oversight, and ch arter renewal and closure decisions. Currently , there is no other comprehensive national database of the roughly 900 charter school authorizers complete with the schools under their authority ; some of these data elements are available from public documents, but they are not made available to the public consistently across all authorizers. There is also no other comprehensive, full y- populated tool for tracking the activities of and evaluating the quality of authorizers nationwide based on their authorizing decisions in light of schools’ performance. This survey will be administered across the entire universe of charter school authorizers. **2. Indicate how, by whom, and for what purpose the information is to be used. Except**  **for a new collection, indicate the ac tual use the agency has made of the information**  **received from the current collection.** The National Charter School Resource Center (Charter School Center) will be administering the necessary survey , collecting the resulting information, and maintaining the authorizer database. The Charter School Center is contracted b y the US Department of Education’s Office of Charter Schools to provide resources and information to the public and charter school stakeholders in pursuit of the Charter School Program’s statuto ry mission. Contractor staff will collect data from all of the nation’s charter authorizers. The data will focus on their respective schools and fall2

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- 0023 Revised: 1/ 17 /201 4 within the following general categories: characteristics of schools under their authority, renewal/closure cycles and decisions, related reasons for renewal or closure, and other information around authorizers’ renewal, closure, and interim policies and practices. These data will be collected annuall y via on

- line survey s (highl y preferable) and paper surveys. The on

- line survey

link will be provided to respondents via e

- mail correspondence and on the mailed paper survey
. The purpose of this project is for the Charter School Center to maintain and implement a publicly available charter school authorizer database that aligns authorizer data with individual charter school data. This database will enable policy makers, educators, researchers, and the public to know at a glance all historic and upcoming authorizer decisions. It will also enable these audiences to better understand whether individual authorizers are making charter renewal an d closure decisions. In formation from the survey in the past has been used to connect charter schools with authorizers, and to provide data for the Department’s EDFacts sy s tem. **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 respo nses, 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 will be administered with both a paper survey instrument mailed to respondent s and electronic completion and submission via the Charter School Center website at www.charterschoolcenter.org. The paper survey instrument will include instructions on how to access and complete the electronic version of the survey . Electronic completion and submission will greatly

reduce the recordkeeping and data entry burden, so this method will be encouraged. However, expert input from a Charter School Center advisory board member indicated that mailing the paper survey

to respondents served several purposes: 1) it serves as a phy sical reminder that the survey

needs to be completed; 2) it serves as an organization tool on which respondents can gather all of the necessary information before entering it into the online version; 3) for the percentage of respondents that are not able or do not wish to complete the survey electronically , it provides another way to collect the information. **3. Describe ef** 

**forts to identify duplication. Show specifically why any similar**  **information already available cannot be used or modified for use for the purposes described in**  **Question 2**  **above.** There is no comprehensive national database of the roughly 900 charter school authorizers complete with the s chools under their authority currentl y in existence. Also, there is currentl y no comprehensive, fully

- populated tool for evaluating the quality of authorizers nationwide based on their authorizing decisions in light of schools’ performance. The National As sociation of Charter Authorizers (NACSA) will provide the Charter School Center with the list of approximately

900 authorizers and the charter schools that they authorize, which avoids duplication of effort around basic data collection for those authorizer s and their schools. Support staff will follow up with non

- respondents six weeks after survey administration by

phone or3

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- 0023 Revised: 1/ 17 /201 4 email and encourage potential respondents to complete the survey electronically

or, in some cases, b y phone. The survey

instrument was tested on six potential respondents in early October 2010. These respondents provided feedback on ease of completion and question comprehension, and feedback was incorporated into the final survey instrument. Currently , some authorizer date is being incorp orated in the EDFacts data collection, collecting the authorizer name and type for each charter school. This addition will first be collected with the SY 2013

- 2014 data set, and will ensure the Department receives this data on all charter schools in the c ountry . However, these additions do not include the more detailed information provided b y the survey, particularl y renewal information and closure reasons. **4. If the collection of information impacts small businesses or other small entities,**  **describe any met hods 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 t hat 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.** Many charter school authorizers are local school districts, and so range in size from small to very large. Authorizers are also State Educational Agencies, universities, and other non

- profits and governmental organizations. As a rule, smaller entities generall y authorize fewer schools, making the amount of information collected proportionate to the authorizer’s size. Moreover, the information collection represents a very minimal burden to each authorizer (0.5 to 4.0 hours annually depending on the number of schools authorized). The requested information is intrinsic to an authorizer’s operations and should be readily available to these entities. **5. Describe the consequences to Federal program or policy activities if the collection is**  **not conducted or is conducted less f requently, as well as any technical or legal**  **obstacles to reducing burden.** As stated above, The U.S. Department of Education has as one of its important policy goals expanding the number high

- quality public school choice options. Specifically , the Charter School Program office within the Office of Innovation and Improvement is at the forefront of efforts to achieve this goal. Charter school authorization is inherently a critical component of successfull y doing so because these are the state and local bodies that have the authority to grant, monitor, oversee, renew and close public charter schools. Thus, a means for stakeholders to be able to access objective information about authorizers based on their decision

- making in light of the performance of schools under their charge is essential to achieving the high

- quality public school choice goals of the U.S. Department of Education. If this information is not collected, it would be extremely

difficult, if not impossible, for stakeholders to access and utilize th is information on a national scale. **6. 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;** 4

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 **requiring respondents to prep are 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, gove rnment**  **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 statistica l 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**  **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 demonstrat**  **e that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.**  There are no special circumstances that require the information collection to be conducted in any of the manners described above. **7. 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 obt ained**  **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**  **ci rcumstances should be explained.**  The survey

published a 60

- and 30

- day Federal Register No tice; during the 60

- day Federal Register published on November 16, 2010 in volume 75 page 69 425 OII received two public comments. Submitted comments included requests to add addition al data elements to the survey , specificall y to provide more information on the charter schools identified. Changes to the survey instrument were not made based on these comments. Adding additional data elements would significantl y increase the burden on authorizers completi ng the survey , lower the survey completion rate, and are not necessary to determine initial c harter authorizations, on

- going5

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- 0023 Revised: 1/ 17 /201 4 monitoring and oversight, and charter renewal and closure d ecisions. One comment suggested the addition of a question regarding how many charter applications the authorizer has received since 2005; with OII concurrence this question was added to the instrument. The definition of “alternative” was changed to delete the reference to students on an Individualized Education Program (IEP). The Charter School Center consulted with charter school authorizers as well as representatives from the National Association of Charter School Authorizers (NACSA). Specificall y, draft surveys were disseminated to a small sample of charter authorizers and NACSA staff to yield feedback on structure, clarity , user - friendliness and potential for high return rates. Several revisions were made to the survey instrument in light of the feedback gained through the process
. Through the first three years of survey implementation, updates were made annually based on feedback from respondents and advisory board members. All updates were minimal and did not impact the burden of the survey , but did aid in clarification, and completeness of the response to the survey
. **8. Explain any decision to provide any payment or gift to respondents, other than**  **remuneration of contractors or grantees with meaningful justification**  **.** No gifts or pay

ments will be made to respondents. **9. 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 ICRAS’ Part 2 IC form**  **. A confidentiality statement with a legal citation that authorizes the pledge**  **of confidentiality**  **should be provide d.**  **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 Responsibiliti**  **es 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,**  **Us e 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 make**  **s no pledge about the confidentially of the data.**  No assurance of confidentiality is provided as the information is public. **10. Provide additional justification for any questions of a sensitive nature, such as**  **sexual behavior and attitudes, reli gious 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 f rom whom the information is**  **requested, and any steps to be taken to obtain their consent.** No questions in this information collection are of a sensitive nature.6

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- 0023 Revised: 1/ 17 /201 4 **11. Provide estimates of the hour burden of the collection of information. The**  **statement should:**
 **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**  **Question 12. Unless directed to do so, ag**  **encies 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 appro val covers more than one form, provide separate hour**  **burden estimates for each form .**  **(The table should at minimum**  **include Respondent types,**  **Number of Respondent**  **s and Responses, Hours/Response, and**  **Total Hours)**
 **Provide estimates of annualized cost to respo ndents 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 Question**  **14.** This information request covers one form. Number of respondents (estimated) : 900 Frequency

of response : once annually Annual hour burden: 2.25 hours on average, depending on number of charter schools authorized (more schools will increase the burden) and ease of authorizer re cord retrieval. (Expected range of burden is 0.5 to 4 hours per authorizer.) How was this burden estimated?: This burden was estimated based on the length of the survey and consultation with indiv iduals who are familiar with authorizing practices, to determine approximate survey

completion time. Annual cost to respondents: $35 per hour ; $78.75 per respond ent, on average; $70,875 across all respondents annually
. This amount is expected to be reduc ed b y 50% after the first year, as the incremental information needed will be considerably less. **12. 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 o f any**  **hour burden shown in Question**  **s 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** 7

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**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 acq uisition,**  **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 a**  **nd 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 varian**  **ce. 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 p**  **ublic 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 ther**  **eof, 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**  **Question 12**  **. Total Annualized Capital/Startup Cost:**  **Total Annual Costs (O&M): Total Annualized**  **Costs Requested:** There is no capital, start

- up, or maintenance cost to respondents. a) For the Charter School Center, (who will hold and maintain the database) start

- up cost of the database is estimated at $85,000 in the first year. To accomplish database construction, the Charter School Center estimates a total of 1,159 hours are needed from two information technology

support staff. These staff hours comprise the total start

- up cost of developing the database infrastructure. Additional start

- up costs wil l not be necessary for survey

renewal. b) The approximate cost of on

- going annual maintenance and data collection is $65,000 per year. This cost is comprised of: 1,166 staff hours at $62,000 , Supplies (for administering paper survey) at $3,000

. Total $6 5,000
. Therefore the total cost of information collection over three ye ars is: First year $65,000

Second year $65,000 Third year $65,0008

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- 0023 Revised: 1/ 17 /201 4 **13. 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**  **Questions 12, 13, and 14 in a single table.**  Additional cost to the Federal government, excluding Item 13, is $0 Aggregate cost estimate from Items 12, 13, and 14 12. Cost to respondents, year 1 : $70,875 13. Total annual cost burden, year 1 : $ 65,000 14. Cost to the Federal government: $0
**14. 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 s ize 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 res pondent universe, etc.). 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 cost s**  **(if applicable) .**  There are no requested program changes or adjustments; this is a reinstatement without change. While minor changes were made each ye ar of implementation, as described in Question 7, no additional changes are requested at this time. **15. For collections of information whose results will be published, outline plans for**  **tabulation and publication. Address any complex analytical techniques that will be used.**  The information will be published via a s earchable database available at www.charterschoolcenter.org , or at a similar site to be developed . No complex analy tical techniques or statistical methods will be used. **16. Provide the time schedule for the entire project, including beginning and en**  **ding dates of the collection of information, completion of report, publication dates, and**  **other actions.** Year 1 Schedule Task Completion date Survey renewal December 2013 Survey administration Summer 20149

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- September 2014 Database updated September 2014
**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.** The expiration date will be displayed on the information collection. **18. Explain each exception to the certification statement identified in the Certification**  **of Paperwork Reduction Act.** There is no exception to the certifications.