EDGAR Recordkeeping and Reporting Requirements

Table I for 1890-NEW Supporting Statement

Recordkeeping and Reporting Requirements in the

Education Department General Administrative (EDGAR) Regulations

“CFR” refers to Code of Federal Regulations.

Section of 34 CFR	Title	Description of Recordkeeping or Reporting Requirement	Recordkeeping Burden Hrs.	Reporting Burden Hrs.
74.25	Budget/ program revisions.	Part 74 of EDGAR applies to Institutions of Higher Education (IHEs), nonprofit organizations (NPOs), and hospitals. Of the approximately 11,000 discretionary grants (new and non-competing continuation grants) that ED awards annually, 6400 grants were awarded to IHEs, NPOs, and hospitals. Under 34 CFR 74.25 of EDGAR, very few project revisions require prior approval. It is estimated that ED will receive approximately 1100 prior approval requests from grantees per year (represents 10% of the 11,000 grants awarded annually) and that approximately 640 of those requests will be submitted by IHEs, NPOs, and hospitals (represents 10% of the approximately 6,400 grants awarded to IHEs, NPOs and hospitals annually). Additionally, under 34 CFR 75.261, all types of grantees including State Educational Agencies (SEAs), Local Educational Agencies (LEAs), and Federally Recognized Indian Tribal Governments may follow the regulations in 34 CFR 74.25 (e)(2) regarding extension of a project period. Section 74.25 (e)(2) allows grantees to initiate a one-time extension of their projects’ expiration date of up to 12 months without prior approval from ED. Grantees, however, must notify the Department that they intend to extend their grants and indicate the supporting reasons for the extension and the revised expiration date. Based on FY 2006 time extension data from the Grant Administration and Payment System (GAPS), approximately 2,555 grantees annually will receive this one-time extension of up to 12 months of their project periods. REPORTING BURDEN		(Prior Approval Requests: 640 responses x 1 hr. = 640 hrs.) (Time Extension Notifications: 2,555 responses X 1 hr. = 2555 hours) Total Reporting Burden Hours for 34 CFR 74.25 = 3195 hours
74.44	Procurement Procedures.	It is estimated that approximately 20% (1280) of the 6,400 IHE, NPO and hospital recipients must keep records on procurement actions under their discretionary grants. RECORDKEEPING BURDEN	1,280 responses x 10 hrs. = 12,800 hrs.
74.45	Cost and price analysis.	Justification and burden hours for 34 CFR 74.45 are included under 34 CFR 74.44.
74.46	Procurement records.	Justification and burden hours for 34 CFR 74.46 are included under 34 CFR 74.44.
74.47	Contract Adminis-tration.	Justification and burden hours for 34 CFR 74.47 are included under 34 CFR 74.44.

Table I for 1890-NEW Supporting Statement

Recordkeeping and Reporting Requirements in the

Education Department General Administrative (EDGAR) Regulations

Section of 34 CFR	Title	Description of Recordkeeping or Reporting Requirement	Recordkeeping Burden Hrs.	Reporting Burden Hrs.
74.72	Subsequent Adjustments.	It is estimated that approximately 10% (640) of the 6400 IHE, NPO and hospital recipients would have to make subsequent adjustments to records due to audits or other reviews. RECORDKEEPING BURDEN	640 responses X 10 hours = 6400 hrs.
75.119 cross referen-ced to 76.656	Information needed if private school students participate.	It is estimated that approximately 10% (1100) of 11,000 ED discretionary grant recipients include students from private schools in their applications. This information would be a part of the original application narrative. REPORTING BURDEN		1100 responses x 1 hr. = 1100 hrs.
75.261	Extension of a project period.	It is estimated that annually, approximately 240 grant recipients will request a second (or more) extension of their project periods that requires prior approval from ED (based on FY 2006 time extension data from GAPS). Note that recipients under the four National Institute on Disability and Rehabilitation Research programs listed in 34 CFR 75.261 (b) of EDGAR must request prior approval for any time extension. The burden hours for any of these NIDRR grantees that request and receive a time extension are included with the burden hour calculations for one-time extension listed above under 34 CFR 74.25. REPORTING BURDEN		240 responses X 1 hr.= 240 hrs. (Note: the burden hours for time extension requests for grantees in the NIDRR programs listed under EDGAR, 75.261 (b) are included with the burden hours for one-time extensions listed under 34 CFR 74.25 (e)(2)).
80.30	Changes.	It is estimated that approximately 10% (460) of 4600 State Educational Agencies (SEAs), Local Educational Agencies (LEAs) and Federally-Recognized Indian Tribal Governments will request changes to their projects that require prior approval from ED. Very few changes require prior approval and information from grantees. REPORTING BURDEN		460 responses x 1 hr. = 460 hrs.
80.36	Procurement.	It is estimated that approximately 20% (920) of the 4600 SEA, LEA and tribal government recipients must keep records on procurement actions under their discretionary grants. RECORDKEEPING BURDEN	920 responses x 10 hours = 9200 hrs.
		TOTAL BURDEN HRS. = 33,395	Total Recordkeeping Burden Hours = 28,400	Total Reporting Burden Hours = 4,995

NOTE:

• The burden hours for the following EDGAR sections are accounted for in the burden hour calculation for the ED 524B and not included in this table (see separate Supporting

Statement (1890-0004) for the burden hour calculation for the ED 524B):

34 CFR 74.51, 75.118, 75.590, 75.720, and 80.40

• The burden hours for 34 CFR 75.117 are accounted for in the burden hour calculation for the ED 524 and not included in this table (see separate Supporting Statement for the burden hours calculation for the ED 524 (1890-NEW)).

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