Att_GGApplicationStatemnt_10_LEAP

Supporting Statement
Application to Participate in the Leveraging Educational Assistance Partnership (LEAP), Special
Leveraging Educational Assistance Partnership (SLEAP), and the Grants for Access and
Persistence Programs for the 2010-2011 Award Year
(ED FORM 1288)
A. JUSTIFICATION
1.

The Leveraging Educational Assistance Partnership (LEAP), Special Leveraging
Educational Assistance Partnership (SLEAP), and Grants for Access and Persistence
(GAP) Programs are authorized under Title IV, Part A, Subpart 4 of the Higher Education
Act of 1965, as amended (20 U.S.C. 1070c), and administered under 34 CFR Part 692.
Section 415C(a) of the Higher Education Act of 1965, as amended (HEA), requires a
state to submit an annual application to participate in these programs. The GAP Program
was authorized under Section 415E, which was amended as a result of the Higher
Educational Opportunity Act of 2008 (HEOA).
The GAP Program replaces the SLEAP Program previously authorized by section 415E
of the HEA, however, section 415E(j) of the HEA, as amended by the HEOA, provides
that for the two-year period that began on August 14, 2008, the date of enactment of the
HEOA, a State may continue to make grants under the SLEAP Program, i.e., through the
2010-2011 award year. This is the last award year in which States will be able to apply
for SLEAP funding. States that choose to apply for either SLEAP or GAP funding and
be considered must first apply for LEAP funding and be deemed eligible. Therefore, the
new application to participate in the GAP Program has been combined with the
previously approved ED form 1288 used to apply under the LEAP and SLEAP programs.
Combining the forms keeps the burden on the applicants to a minimum and makes
managing and delivery of the programs internally, more manageable. The form only
contains items needed to determine a state’s eligibility and assure compliance with
program statute.
Beginning in 2011-2012; states will only be able to apply additionally for GAP Program
funds at which point all SLEAP Program application elements will be removed from this
form. This combined application has been designed utilizing Adobe LiveCycle software.
This new interactive form, allows our State applicants to navigate, complete and apply
for its allotment(s) under the programs 100% electronically.

2.

The officially designated educational agency in each of the 50 States, the District of
Columbia, Puerto Rico, and four island jurisdictions that participate in the LEAP
Program uses this application to apply for funds from the Department on an annual basis.
The information on the application allows states to assure the Department ability to meet
matching and other statutory program requirements. If a state so chooses, it may also
apply to participate in one of the subprograms, SLEAP or GAP. Again, this will be the
last year in which state’s can apply for SLEAP funding. The Department will use this
application information to determine a state’s eligibility for its allotment(s) under these
programs. Failure to receive and process these applications would put the program in
default of congressional intent and in violation of the program statute.

3.

The new, combined application has been designed utilizing Adobe LiveCycle software.
This new interactive form, allows our State applicants to navigate, complete and apply
for its allotment(s) under the programs 100% electronically. Upon submission of the
form, states certify and assure the Department that all information given is accurate and
that they will comply with the program statute and regulations. The information the
states are required to provide on the application has been reduced to the bare minimum
required to determine eligibility, program compliance and awarding of allotments.

4.

The LEAP, SLEAP and GAP programs are operated by a single agency in each state.
Each state provides annual information on the application that applies only to that state
and is not collected on any other form. Therefore, there is no duplication collection of
this data. Again, in the development of this form, we only require the bare minimum of
items needed to ensure compliance with the programs in order to make LEAP, SLEAP
and GAP program grant awards.

5.

The collection of information does not involve small businesses or other small entities.

6.

States are required to apply annually for their LEAP, SLEAP and GAP program
allotments. Again, we only ask for bare minimum of items needed to ensure compliance
with the LEAP and SLEAP and GAP programs statute and make allotments to states
under the programs. In the development of this form, we added enough information
needed additionally to ensure compliance with the GAP Program statute and make
allotments under the new program. Similar information for each state is not available
from any other source that can meet these specific statutory requirements under these
programs. States will use this application to indicate compliance with statutory
requirements and to apply for funds from the LEAP, SLEAP and GAP programs on an
annual basis. The Department will use this application information to determine a state’s
eligibility for its allotment. Failure to receive and process these applications would put
the program in violation of the program statute.

7.

Section 415C(a) of the program statute states, "A state which desires to obtain a payment
under this subpart for any fiscal year shall submit annually an application..."
Consequently, less frequent collection is not a viable option as the programs would be
unable to distribute funds according to the program’s authorizing statute. States will have
sufficient time beyond 30 days to complete and submit this application. States only need
submit an original application electronically and keep a copy for their records.

8.

The states were given an invitation to make comments and suggestions concerning the
development of this form incorporating the GAP subprogram piece and information
collection at the latest National Association of State Student Grant Aid Programs
(NASSGAP) national conference held in St. Pete, Florida October 5 through 7, 2009.
Additionally, the new combined form was forwarded to members of the NASSGAP
Senior Executive committee and other state agency officials inviting them to provide the
Department with comments and suggestions concerning this combined application form.
We have published the relevant federal register notices inviting public comment.

9.

The Department does not provide any payment or gifts to respondents.

10.

No assurance of confidentiality is provided to respondents. The information collected on
the application is part of the state and federal public record.

11.

There are no questions of a sensitive nature.

12.

The 50 States, the District of Columbia, Puerto Rico, and four island jurisdictions are
eligible to participate in the LEAP Program. States must first be found eligible to
participate in the LEAP Program before they can apply to participate in the SLEAP
Program or the GAP Program. Completion of the annual application to participate in the
LEAP and SLEAP or GAP programs is estimated to cost the respondents $ 22,378.
RESPONDENT COSTS
Education Administrator or
Program Specialist

8 hrs x $49.95 x 56 respondents = $ 22,378

56 respondents x 1 submission x 8 hours = 448 annual burden hours
The hourly estimate includes identification of relevant statutory and regulatory
requirements such as estimates of matching and maintenance-of-effort information,
pulling state data, and for states applying for GAP funding, ensuring that all portions of
the written plan have been addressed within the form.
13.

There are no capital or start-up costs for this information collection. All states have
access to Internet and the free Adobe Reader software.

14.

The annual cost to the Federal Government for the processing of this application is
estimated to be $35,616; this cost includes staff time in processing the applications
submitted by states; and analyzing the data for funding decisions and ensuring state
compliance with the program statute.
FEDERAL GOVERNMENT COSTS:
Program Specialist
400 hrs. x $49.30 = $ 19,720
Supervisory, Division Director
200 hrs. x $79.48 = 15,896
$35,616

15.

The annual reporting and recordkeeping hour burden requested increased from 112
burden hours to 448 hours due to additional program requirements under new
subprogram.

16.

Results are not scheduled for statistical use publication.

17.

We are not seeking approval to exclude the display of the expiration date for OMB
approval of the information collection.

18.

No exceptions to the certification statement identified in item 19 of OMB Form 83-I.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection of information does not employ statistical methods.