ED Response to OMB Qs

From: Schubart, Joe [[email protected]]
Sent: Tuesday, February 13, 2007 1:18 PM
To: Potter, Rachel F.
Cc: VerBryckBlock, Karla; Hines, Ralph; Arrington, Angela
Subject: Answers to OMB comments on IEPS 1840-0759

Follow Up Flag: Follow up
Flag Status: Red

Good afternoon Rachel,

 

        Here are the program office's responses to your earlier questions:

-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Wednesday, January 31, 2007 6:33 PM
To: Ingalls, Katrina; Schubart, Joe
Cc: Rudolph, Kim
Subject: OMB comments on IEPS 1840-0759

OMB has the following comments on the subject ICR.   

  

 

 ED cites the reason for the burden change as "Serious effort was made to reduce the amount of information being collected.  Continued communication with the numerous institutions that have been involved with the development of this system has helped obtain positive suggestions for additional improvements to the way this system continues to be refined." This is the reason for any reduction.  What is the reason for the addition of new questions?
 

 [VerBryckBlock, Karla] In August 2006, OMB approved performance and efficiency measures for each of the 14 IEPS programs.  We added new questions, where necessary, to ensure we are collecting the information necessary to "measure" our programs against the approved measures.  We also added questions, where necessary, to make sure we are collecting comparable data across our 14 programs so we can undertake more comprehensive analyses of our programs. 

 

 

  The changes you have made to the collection instrument since the last approval (i.e., those changes that make this submission a revision) are described in the Excel document "IEPS System Required Screens."  The document highlights a number of new data elements and a number of deleted data elements.  Given that things have been both added and removed, please explain why you believe this to be such a drastic net reduction in burden.  (The previous approval of this collection was for 23,523 hours and this request is for 14,136).
[ 

 VerBryckBlock, Karla] We cleaned up the questions to ask them in a more straightforward manner.  We also reduced the size of the fields for collecting the information which reduces the burden.  Also, since this system now being modified and enhanced under a contract, we feel the answers are more accurate than when this was developed under a grant.  We work very closely with the contractor and grantees regarding burden.  

 

 

  Why has the number of responses for this collection doubled (from 2,815 to 5,526)?  Why doesn't this factor alone increase the burden?  

 

 [VerBryckBlock, Karla]  Under the old system, reports were collected in a non-standardized manner (programs had different narrative, data, and budget submission dates).  In the new system, we have standardized the collection so that narrative is submitted in the spring for use with non-competing continuation analysis as is a proposed budget.  In the fall, grantees submit additional narrative (if necessary), all data elements, and a budget expenditure report for the recently concluded year.  This is the reporting structure for all multi-year institutional grants.  The reporting structure for fellowships and the International Research and Studies program is different because of the individual nature of those programs.  In standardizing the reporting structure for most of our programs, it shows an increase in the NUMBER of responses but this in reality places less of a burden on grantees since they are reporting different pieces of information at different times in the year.

 

If you would like us to come over to OMB to provide additional details about this significantly improved system and the rationale behind the changes, please let us know.

 

Thanks!  Karla (502-7632) 

 

Rachel F. Potter

Office of Information and Regulatory Affairs
Office of Management and Budget

Tel: (202) 395-5887

Fax: (202) 395-6974