Supporting Statement

SUPPORTING STATEMENT/JUSTIFICATION

1. JUSTIFICATION

1. 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.

Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP), created in the Higher Education Amendments of 1998 (Title IV, Section 404A-404H), is designed to raise educational expectations and strengthen preparation for college for low-income middle grade and secondary school students through competitively awarded grants to state projects and local partnerships. Grantees (states and local partnerships) provide services including tutoring, mentoring, academic enrichment, student and family support, dissemination of information to students and their parents about postsecondary education and options for financing college, and financial assistance.

The regulations governing the Gaining Early Awareness and Readiness for Undergraduate Programs are 34 CFR Part 694. The Education Department General Administrative Regulations (EDGAR) that requires grantees to submit a final performance report - see 34 CFR Part 74.71 and 34 CFR 80.50.

This Financial Status and Program Performance Final Report is prepared and submitted by GEAR UP grant recipients within 90 days from the end of their 6-year grant performance periods. The information collected in the Final Report allows the Department to determine if a GEAR UP grant project is ready to be closed in “good standing” or needs to remain open for further departmental post award action. Each grantee’s Final Report must communicate or substantiate that the goals of the GEAR UP grant program were achieved. This report is a means for grantees to share the overall experience of their projects and document the achievements and concerns, and describe the effect of their projects on participants being served; project barriers/”lessons learned” and successes/major accomplishments; and evidence of sustainability.

The Final Report is used by the Department of Education (ED) to determine whether recipients of discretionary grants have made substantial progress towards meeting the objective of their respective projects, as outlined in their grant applications and/or subsequent work plans. In addition, the final report enables the Department of Education to evaluate each grant project’s fiscal operations for the entire grant performance period, and compare total expenditures relative to federal funds awarded, and actual cost-share/matching relative to the total amount in the approved grant application.

Furthermore, the GEAR UP Final Report is used to collect data addressing the performance of the program on a national level and thereby includes the information for the Department to use when reporting the program implementation, student outcome, and other required data on the GEAR UP GPRA (Government Performance and Results Act of 1993) performance indicators)

The current Financial Status and Program Performance Report Final Report for the GEAR UP Program (OMB No. 1840-0782) will expire on August 31, 2008.

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 Final Report is completed by each GEAR UP grantee within 90 days after his/her 6-year grant performance period terminates. The Department will use the data collection to ensure compliance with the performance goals and program requirements of GEAR UP.

3. 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.

The Final Report has been converted to a computer-based application. The data collection can now be conducted electronically through a website developed

by ED by Computer Business Methods, Inc., at the following address:

http://opeweb.ed.gov/gearupfpr/codes/guf_login.cfm. Grantees access the report by entering their unique ID and password. They can save their report by sections and submit the report to ED once completed. There are also edit checks on numbers served and automatic totaling of budget information to avoid typographical and computational errors. These changes prevent submission of incomplete and erroneous reports. Hard copies of the Final report are printed from the web-based application and placed in the official file.

4. 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.

GEAR UP’s Final Report is the primary method to collect the overall programmatic and fiscal information from the entire performance period of a project grant, and thereby serve as a GEAR UP grantee’s culminating report. The Final Report collects data on the total federal expenditures and in-kind and financial matching contributions and for each individual year of the project grant. The report serves as the recipients’ means to communicate the overall accomplishments of their projects to determine the impact on the beneficiaries (primarily students), and to display clear evidence of making substantial progress toward achieving the program goals and meeting their proposed project objectives. Furthermore, the Final Report is GEAR UP’s primary method to collect and analyze data on the high school graduation and immediate postsecondary education enrollment rates of the students served by the GEAR UP program.

Since the information submitted is specific to the GEAR UP program, there is no duplication. There is no other data collection instrument available that is critical to meet the purposes described in Items 1 and 2 above.

5. 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.

We continue to anticipate that no small entities will be required to complete this final performance report. The collection of this information has no impact on small businesses or other small entities.

6. 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.

In accordance with EDGAR, 34 CFR §74.71 (institutions of higher education) and §80.50 (state and local governments), and other ED Discretionary Grants policies, a final program performance and financial status report must be submitted by each recipient within 90 calendar days after the date of completion of the grant’s performance period, which is 6 years for GEAR UP state and partnership grants.

The data collection from this Final Report is obtained only during this post-award liquidation period of project grants, during the initial 90-day period after their federal funding from GEAR UP has terminated (i.e., after the performance period end date).

The Department of Education cannot close out a grant award unless it determines that all of the required work of the grant has been completed. The final program performance and financial status report serves to provide such evidence, and convey the extent to which a grant recipient (a) achieved the overall goals of the GEAR UP grant program; (b) implemented the proposed (as indicated in the approved proposal or subsequent workplan) services/activities, met the project’s supporting objectives, and reported information that demonstrates successful achievement of expected grant project outcomes; and (c) with respect to fiscal operations, expended all of the federal funds obligated, and contributed the proposed in-kind and financial resources (cost-share/matching) over the life of the grant.

It is critical for GEAR UP grantees to submit their Final Reports in a timely manner so that the Department can determine if a grant project is ready to be closed in “good standing” or needs to remain open for further departmental post award action. If the grant recipient’s report has not been received or the information in the report does not demonstrate successful achievement of expected outcomes, an ED staff person must follow up with the particular recipient. It must be determined in the follow-up if an oversight occurred, or if the recipient did not meet the grant project’s proposed objectives, and/or if the recipient complied with the GEAR UP program requirements and reporting responsibilities (once a grant project ends).

If the recipient doesn’t respond to the ED staff person’s follow up efforts, by submitting a final report that reflects compliance with the applicable Department regulations and all other terms and conditions of the grant award, and/or making substantial progress in achieving the overall program goals and project objectives, then the ED official must issue a noncompliance letter to the grant recipient.

7. 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;

• 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 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.

There are no special circumstances associated with this data collection. This information collection will be conducted in a manner consistent with established guidelines.

8. 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.

We will publish the appropriate 60 and 30 days Federal Register Notices to allow for public comment.

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

No payment or gifts are provided to respondents.

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

Final Report data will not be confidential. The report does not collect data in which individual students can be identified.

11. 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.

The questions are not of a sensitive nature.

12. 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 not be included in Item 14.

Number of Respondents	Frequency of Response	Hours	Total Burden Hours
175	One time	35	6,125

Number of Respondents	Frequency of Response	Hours	Total Burden Hours	Wage	Total Cost
175	One time	35	6,125	$30 /hour	$183,750

13. 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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) :  .00

Total Annualized Costs Requested : $ .00

The only costs would be for customary and usual business practices.

14. 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.

Activities/Task	Cost	Hours	Number	Total Cost to Fed. Govt.
Final Report Revisions/Form Design once every 3 years	$45/hr	40		$1,800
Securing OMB approval once every 3 years	$45/hr	40		$1,800
GEAR UP staff reviewing Final Reports	$45/hr	4 hrs/FPR	175	$31,500
Technical assistance to grantees (pre and post Final Report)	$45/hr	4 hrs/FPR	175	$31,500
GEAR UP staff processing Final Reports in GAPS and completing other GPOS require-ments	$45/hr	30 hours		$1,350
Preparing and issuing Notifications of Final to grantees and certifying/ authorizing representatives	$45/hr	60 hours		$2,700
Conduct data analysis for GPRA report	$88/hr	24		$2,112
Additional data collection and preparation of coded information	$45/hr	1 hour/FPR	175	$7,875
Totals				$80,637

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

There are no program changes.

16. 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.

The U.S. Department of Education does not plan to publish any information from this collection.

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 U.S. Department of Education will display the expiration date for the OMB approval for this data collection.

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

No exceptions are being requested for this information collection.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on Form 83-I is checked “Yes,” the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:

1. Describe the potential respondent universe (including a numerical estimate) and any sampling or other respondent selection method to be used. Data on the number of entities (e.g., establishments, state and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

2. Describe the procedures for the collection of information, including:

• Statistical methodology for stratification and sample selection.

• Estimation procedure.

• Degree of accuracy needed for the purpose described in the justification.

• Unusual problems requiring specialized sampling procedures, and

• Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

1. Describe methods to maximize response and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield “reliable” data that can be generalized to the universe studied.

2. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.

3. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other persons who will actually collect and/or analyze the information for the agency.

This information collection does not employ statistical methods.

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