Att_Binational Survey Supporting Statement from budget office 4 11 08

Att_Binational Survey Supporting Statement from budget office 4 11 08.doc

Survey on Key Demographics and Needs of the Binational Migratory Children

OMB: 1810-0685

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OMB approval number: (03587)

Expiration date: 06-15-11


SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION


ESEA Title I, Part C, Education of Migratory Children


State MEP Director Survey

Binational Migrant Education Program (BMEP)


1810-0670v.3

A. Justification


Q1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


A1. The U.S. Department of Education (ED) and its Office of Migrant Education (OME) are requesting clearance of a survey of State Directors of the Migrant Education Program (MEP) that would collect additional data on the binational migrant student population. The collection of information is necessary due to the following circumstances: the State MEPs need a better understanding of key demographics and special educational needs of the binational migrant student population. The Binational Migrant Education Program (BMEP) is an effort to support the coordination of activities among the U.S. and Mexican States in order to improve the continuity of educational and educationally - related support services for migrant students who migrate between the two countries. The BMEP was established and operates under the authority of a Memorandum of Understanding [attached] between the Departments of Education in the United States and Mexico. The activities of the BMEP are consistent with the inter-state coordination requirements found in section 1304(a) & (c) of the Elementary and Secondary Education Act (ESEA), as amended by No Child Left Behind Act of 2001. The survey was developed and results will be analyzed under a contract authorized under the inter-state coordination authority found in section 1308(a) of ESEA, as amended [attached].


The requested information on the survey represents the minimum information needed to determine the special educational needs of the binational migrant student population.



Q2. 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.


A2. The information will be used by ED and OME to: (1) identify the special educational needs of binational migrant students, and (2) help coordinate State efforts to design and implement strategies that will improve education outcomes for binational migrant students; and (3) report summary findings to policy-makers in the Administration as well as to State Education Officials, Congress, and the public.



Q3. 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 of using information technology to reduce burden.


A3. The data collection does not require the use of electronic or other technological data collection techniques; however, interviewers may choose to use laptops during interviews and then forward the data in the Word Tables that are in the survey.



Q4. 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.


A4. The requested information is not in any other Federal data collection, and is unique to this program and its grantees. The form is a single document intended to serve the purpose of determining the special educational needs of the binational migrant student population and inform the development and implementation of strategies that will improve their educational outcomes.


Q5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.


A5. Small businesses and other small entities are not impacted by this data collection.



Q6. 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.


A6. If this collection is not conducted, ED will be unable to identify and assess the key demographics and special educational needs of binational migrant students. Therefore, ED will be unable to: (1) help coordinate States’ efforts to improve their educational services and academic achievement; and, (2) determine whether and what changes and improvements should be made to the program.



Q7. Explain any special circumstance 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 that 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.


A7. There are no special circumstances that require the collection to be conducted in a manner inconsistent with the requirement of 5 CFR 1320.5.



Q8. 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.


A8. Consultation was conducted on October 9, 2007 with several (fewer than 10) State MEP Directors regarding the availability of data and the level of burden associated with this collection. The 60-day comment notice will be posted in the Federal Register.



Q9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees


A9. No gift or payment will be made to respondents.



Q10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulations, or agency policy.


A10. No assurance of confidentiality is provided.



Q11. 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. This 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.


A11. There are no questions of a sensitive nature in this collection of information.



Q12. 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.


  • 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 be included in Item 14.


A12. See tables on following page.







A 12. Table 1


Estimated Burden Hours

This estimate includes the time that SEA staff will need to administer the survey.


Number of Hours

Number of Students/Respondents

Total Hours


Total Hours

Number of SEAs

Total Number of Hours per Year








.5

(x) 50

= 25


25

(x) 8

= 200 hrs.

Year 1








.5

(x) 50

= 25


25

(x) 21

= 525 hrs.

Year 2








.5

(x) 50

= 25


25

(x) 21

= 525 hrs.

Year 3

Total Estimated Burden Hours for 3 Years: = 1,250


A 12. Table 2

Estimates of Annualized Cost to Respondents


Year


Number of Hours

Respondent Cost per Hour

Number of

SEAs/ Submissions

Cost

Note







Equivalent to the pay of a GS-10/07

1


25 (x)

$30.17 (x)

8

= $6,034.00







2


25 (x)

$30.17 (x)

21

= $15,839.29







3


25 (x)

$30.17 (x)

21

= $15,839.29

Total for 3 Years: = $ 37,712.50











Q13. 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 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.


A13. Not applicable.



Q14. 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.











A 14. Table 1

Costs For Contractor Personnel (3 Year Time period)

(Based on contractor’s loaded cost rate of $600 per day)

Purpose

Number of Days

Cost per Day

Total

Frequency


  • Survey Development

7

$600.00

$4,200.00

One Time

  • Sampling

  • Training to States & Administration

26.5

$600.00

$15,900.00

Annually

  • Analyze Data

5

$600.00

$3,000.00

Annually

Preparation:

  • Drafts

  • Final Reports

  • Presentation Materials

8

$600.00

$4,800.00

Annually

$23,700.00 Annual Subtotal


A 14. Table 2


Cost For ED Staff

(Assuming Rate of GS 13/10 @ $409.44 per day)


Purpose

Number of Days

Cost per Day

Total

Frequency

  • Review

  • Comment

  • Edit Draft Materials

3

$409.44

$1,228.32

Annually

A 14. Table 3

Estimated Annualized Federal Cost

(Over 3 years of data collection authority)


$4,200.00 (one time) + $23,700.00 + $1,228.32

= $29,128.32

Year 1


$23,700.00 + $1,228.32

=$ 24,928.32

Year 2


$23,700.00 + $1,228.32

=$24,928.32

Year 3




$ 29,128.32 + 24,928.32 + 24,928.32

=$ 78,984.96

Total: Years 1-3



Q15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.


A15. This is a new collection.



Q16. 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.


A16. The data will be summed and/or averaged across States. National and State-by-State results will be developed by an ED contractor and shared with officials in the Administration, States, Congress and the public through oral presentations and written materials provided by ED staff. We estimate that the data will be collected annually in early September, and analysis and summary materials will be developed and released annually in October.



Q17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


A17. The expiration date will be displayed on the application package.



Q18. Explain each exception to the certification statement identified in Item 20, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.


A18. There are no exceptions to the certifications.



  1. Collections of Information Employing Statistical Methods

This collection will only employ statistical methods in the selection of students using structured samples.

Sampling Population: While there are 48 states that have MEPs, only 21 states have been selected to conduct the survey because some states do not have enough students to participate in an intensive data collection, such as the Binational Student Survey. Also, noting that this is a voluntary survey, only eight states are selected for the first year to serve as a pilot for the next two years. After conducting the survey with just eight states the first year, we anticipate being more knowledgeable and efficient when conducting the survey with 21 states the subsequent two years. For these same reasons, we have chosen not to survey all the 195,000 students.

Sampling Source: The survey administrators will cross-reference data collection systems for migrant students (i.e. NGS, MIS2000, CoeStar, etc.), Certificates of Eligibility (COEs), other district student information databases, and conduct interviews.

Sampling Procedure: Within each participating State, a structured sample will be drawn to ensure that appropriate numbers of students are selected representing the five age/grade categories pertinent to the survey: (1) birth through pre-kindergarten, (2) grades K-5, (3) grades 6-8, (4) grades 9-12, and (5) out-of-school youth (OSY). The percentage of students in each of these categories will equal the percentage of students in each category that are found in the state’s binational student population. Within these categories, students will be chosen randomly for inclusion by using a table of random numbers generated from an Excel spreadsheet or other recognized sampling tool. Sixty students will be selected using these procedures in each state except for California where 100 students will be selected..


Directions


  1. Identify all binational children who made a qualifying move from Mexico to the U.S. during the time period of September 1, 2006 to August 31, 2007.

  2. Categorize all children identified in Step A into five categories: (1) birth through pre-kindergarten, (2) grades K-5, (3) grades 6-8, (4) grades 9-12, and (5) out-of-school youth (OSY).

  3. Calculate the percent of children in each category. (# in category/Total number identified in Step A). Example: 30 Pre-K students/100 total identified students = 30%.

  4. Multiply the percent of children in each category by 60 (100 in California) to determine the number of students to be selected in each category. Example: 30% X 60 = 20 Pre-K students to be included in sample

  5. Create a numbered list of students for each of the five categories.

  6. Create five sets of random numbers from an Excel spreadsheet or other recognized sampling tool where the quantity of numbers to be chosen is the number calculated in Step D and the limit is the number of children identified in Step B.

  7. Select those students from the numbered lists that match the numbers generated in Step F.

Please Note: All survey administrators will receive a training manual and participate in training sessions to receive instructions on how to administer the survey.

Relevant sections from ESEA State MEPs inter-state coordination responsibilities & ED’s authority to contract to support interstate coordination in the MEP:

ESEA SEC. 1304. STATE APPLICATIONS; SERVICES.

(a) APPLICATION REQUIRED– Any State desiring to receive a grant under this part for any fiscal year shall submit an application to the Secretary at such time and in such manner as the Secretary may require.

(b) PROGRAM INFORMATION- Each such application shall include—


. . .


(3) a description of how the State will use funds received under this part to promote interstate and intrastate coordination of services for migratory children, including how, consistent with procedures the Secretary may require, the State will provide for educational continuity through the timely transfer of pertinent school records, including information on health, when children move from one school to another, whether or not such move occurs during the regular school year;


. . .


(c) ASSURANCES- Each such application shall also include assurances, satisfactory to the Secretary, that—

(1) funds received under this part will be used only—


. . .


(B) to coordinate such programs and projects with similar programs and projects within the State and in other States, as well as with other Federal programs that can benefit migratory children and their families;


ESEA SEC. 1308. COORDINATION OF MIGRANT EDUCATION ACTIVITIES.

(a) IMPROVEMENT OF COORDINATION-

(1) IN GENERAL- The Secretary, in consultation with the States, may make grants to, or enter into contracts with, State educational agencies, local educational agencies, institutions of higher education, and other public and private nonprofit entities to improve the interstate and intrastate coordination among such agencies' educational programs, including the establishment or improvement of programs for credit accrual and exchange, available to migratory students.

(2) DURATION- Grants under this subsection may be awarded for not more than 5 years.




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