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ICRAS ICR ID and OMB Number: 201101-1855-001 and 1855-0023

Revised: 1/17/2014

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 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.

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. Specifically, 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 highquality 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 because charter school authorizers 

are the public entities primarily responsible for: initial charter authorizations, on-going 

monitoring and oversight, and charter 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, fully-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 actual 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 by 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 statutory mission. Contractor staff will collect data from 

all of the nation’s charter authorizers. The data will focus on their respective schools and fall 
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ICRAS ICR ID and OMB Number: 201101-1855-001 and 1855-0023

Revised: 1/17/2014

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 annually via on-line surveys (highly 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 policymakers, 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 and 

closure decisions. 

Information from the survey in the past has been used to connect charter schools with 

authorizers, and to provide data for the Department’s EDFacts system.

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 will be administered with both a paper survey instrument mailed to 

respondents 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 physical 

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 efforts 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 schools under their authority currently in existence. Also, there is currently no 

comprehensive, fully-populated tool for evaluating the quality of authorizers nationwide based 

on their authorizing decisions in light of schools’ performance. The National Association 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 authorizers and their schools. Support 

staff will follow up with non-respondents six weeks after survey administration by phone or 
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email and encourage potential respondents to complete the survey electronically or, in some 

cases, by 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 incorporated 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 country. However, these additions do not include the more detailed information 

provided by the survey, particularly renewal information and closure reasons.

4. 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 notfor-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.

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 generally 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 frequently, 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 

successfully 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 this 

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;
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 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 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 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 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 survey published a 60-and 30-day Federal Register Notice; during the 60-day Federal 

Register published on November 16, 2010 in volume 75 page 69425 OII received two public 

comments. Submitted comments included requests to add additional data elements to the survey, 

specifically 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 

significantly increase the burden on authorizers completing the survey, lower the survey

completion rate, and are not necessary to determine initial charter authorizations, on-going 
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Revised: 1/17/2014

monitoring and oversight, and charter renewal and closure decisions. 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). 

Specifically, 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 payments 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 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 as the information is public.

10. 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.

No questions in this information collection are of a sensitive nature.
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ICRAS ICR ID and OMB Number: 201101-1855-001 and 1855-0023

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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, 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. (The table should at minimum include 

Respondent types, Number of Respondents 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 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 record 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 individuals who are familiar with authorizing practices, to determine 

approximate survey completion time. 

Annual cost to respondents: $35 per hour; $78.75 per respondent, on average; $70,875 across all 

respondents annually. This amount is expected to be reduced by 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 of any 

hour burden shown in Questions 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 
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ICRAS ICR ID and OMB Number: 201101-1855-001 and 1855-0023

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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 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 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 will 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 $65,000. Therefore the total cost of information collection over three 

years is: 

First year $65,000 

Second year $65,000 

Third year $65,000 
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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 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.). 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).

There are no requested program changes or adjustments; this is a reinstatement without change. 

While minor changes were made each year 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 searchable database available at 

www.charterschoolcenter.org, or at a similar site to be developed. No complex analytical 

techniques or statistical methods will be used. 

16. 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.

Year 1 Schedule

Task Completion date 

Survey renewal December 2013

Survey administration Summer 2014
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ICRAS ICR ID and OMB Number: 201101-1855-001 and 1855-0023

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Data collection and entry August-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.