SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
Andrea C. Baird
MARCH 7, 2011
A. 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.
This information collection is required under regulations governing the Teacher Quality Enhancement Grants Program (TQE), as authorized by the Higher Education Act (HEA) of 1965, as amended in 1998.
The U.S. Department of Education (ED) is requesting an extension of a currently approved collection. The purpose is to continue implementing the requirement that students in teacher preparation programs who receive scholarships under TQE must repay those scholarships if they do not teach in high-need local educational agencies (LEAs) for the same time period that they received financial assistance. This requirement is found in section 204(e) of the HEA, as amended, Public Law 105-244. A copy of the statute is attached.
In addition, the regulations governing TQE include the following specific provisions requiring the collection of this information:
Section 611.41 describes the circumstances under which an individual may receive a scholarship to attend a teacher training program and spells out the terms and conditions that will be binding on the recipient.
Section 611.42 describes how the period of service for the scholarship recipient will be determined and the information that ED will need from the institution of higher education (IHE) that awards the scholarship and from the high-need LEA where the scholarship recipient ultimately teaches.
Section 611.43 describes the consequences of a scholarship recipient’s failure to meet the service obligation.
Section 611.44 describes the circumstances under which the Secretary may defer a scholarship recipient’s service requirement and the process for obtaining renewal of the deferment.
Section 611.45 describes the circumstances under which the Secretary may discharge a scholarship recipient’s obligation to repay a scholarship.
Section 611.46 describes the scholarship recipient’s reporting responsibilities with regard to his/her employment with a high-need LEA or request for a deferral.
Section 611.47 describes a scholarship recipient’s reporting responsibilities upon the close of the LEA’s academic year.
Section 611.48 describes the scholarship recipient’s reporting responsibilities upon failure to graduate or withdrawal of scholarship support.
Section 611.49 describes the grantee’s responsibilities for implementing the scholarship requirements before awarding a scholarship. These responsibilities include insuring recipients understand and execute the terms and conditions of ED’s approved scholarship agreement.
Section 611.50 describes the grantee’s responsibilities in helping to implement the scholarship requirements. These responsibilities include providing specific information to ED concerning the recipients when they are first accepted in the program and providing information to ED concerning any recipient’s graduation or withdrawal from the program.
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 purpose of this information collection is to: 1) identify the recipients of financial assistance provided by TQE; 2) subsequently track the employment history of these individuals to ensure that they are in compliance with program requirements; 3) enable recipients—as appropriate—to request deferments of their service obligation or a repayment schedule, if they become obligated to repay their scholarships; and 4) track scholarship recipients who default on their obligation and to pursue collection of funds from these individuals.
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.
OPE worked with ED’s Office of the Chief Information Officer (OCIO) for the development of an electronic system that will support the collection of TQE scholarship monies from individuals whose scholarships convert to loans when they choose not to teach in a high-need area after graduation and certification. TQE commissioned an online database system called the Title II Scholarship Administration and Reporting System (TSAR). Data about the recipients is entered into the TSAR, and is easily searchable to obtain the most current information on the status of the recipient. The system has been live since September 2008, and replaces an earlier Access database.
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.
Because data collected are specific to recipients of TQE scholarship funds, there is no similar or duplicate collection occurring. The information and purposes described in Item 2 are distinctive to this program.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The application does not involve the collection of information from small businesses or other small entities. Only institutions of higher education, high-need state and local school districts (SEAs and LEAs), and non-profit organizations providing TQE scholarships, as well as postsecondary teacher education students receiving scholarship assistance under the TQE program are affected by this collection.
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.
The reporting and record-keeping requirements are the minimum required to implement the program statute and program regulations. To require that they be performed on a less frequent basis would reduce ED’s ability to effectively administer the program in accordance with statutory and regulatory provisions, and is apt to result in an inability to recover funds from scholarship recipients who fail to abide by the terms of their scholarships.
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 that 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 that would require the collection to be conducted in any other manner other than that listed above.
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.
Representatives outside ED were consulted with regard to the documents in the most recent collection in 2008. No comments were received -- no significant problems were identified, and the original estimates of record-keeping burden were seen as generally accurate.
In addition, feedback is consistently solicited from both grantees and scholarship recipients, such as during a] special sessions at grantee meetings (such as the December 2006 TQE project directors meeting, and the October 2007 TQE meeting for FY 2007 TQE-Recruitment grantees); b] TQE meetings targeted to grantees administering scholarships (e.g., such as the March 21, 2007 meeting that focused exclusively on scholarship regulations, policies, practices, and documents); c] specialized meetings (such as the Sept. 28, 2005 teleconference-workshop for FY 2005 grantees administering TQE-funded scholarships) and more general technical assistance conference calls; and d] during on-site monitoring visits. No significant problems have been identified, and the original estimates of record-keeping burden have been seen as generally accurate. A 60 day notice was published in the Federal Register on January 4, 2011 – 76 FR 338. No public comments were received. A 30 day notice was published in the Federal Register seeking public comment.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts will be made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
In order to implement the requirements of the statute, confidential information on scholarship recipients will be collected. Specifically, the IHE will report to ED the name, address, social security number, and date of birth for each recipient at the time a scholarship award is made. These data will be used to track students after the completion of their studies (or withdrawal from the program) to ascertain whether they are fulfilling the teaching requirement of their award.
Any data that is required and maintained by ED itself will be maintained in accordance with the Privacy Act of 1974, as amended. To assure that sensitive data about scholarship recipients are not compromised, all data—whether submitted electronically or as hard copy—will be maintained in a secure location. Access to these data will be limited only to staff who are directly responsible for working with TQE and this information is only available onsite at the TQE office via desktop computer.
As noted in the Privacy Act of 1974 (5 U.S.C. 552a), the authority for collecting the requested information from and about TQE scholarship recipients is Title II, Section 204(e) of the Higher Education Act of 1965, as amended by the 1998 Higher Education Amendments, and 31 U.S.C. Chapter 37. IHE students are advised that participation in the Teacher Quality Enhancement Grants scholarship program is voluntary and that giving the Department their Social Security Numbers (SSNs) is voluntary, but they must provide the requested information, including their SSNs, to participate. The information will be used to ensure that recipients of scholarships provided with funds under Title II of the Higher Education Act subsequently: (1) complete a teacher education program and teach in a high-need school of a high-need local educational agency for a period of time equivalent to the period for which the recipient received scholarship assistance; or (2) repay the amount of the scholarship. The information in students’ records may be disclosed to third parties as authorized under routine uses in the appropriate systems of records, either on a case-by-case basis, or, if the Department has complied with the computer matching requirements of the Privacy Act, under a computer matching agreement.
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 Department is not requesting any sensitive data.
12. Provide estimates of the hour burden of the collection of information and estimated costs to respondents.
Respondents (for reporting and/or recordkeeping purposes) under this provision include: 1) IHEs that provide scholarship contractual agreements and addenda (to prior contracts); 2) teacher education students who receive scholarship assistance under the program; and 3) high-need LEAs that employ scholarship recipients. The estimated annual record-keeping and reporting burden extends to these three groups. Based on changes due to the 2008 reauthorization of the Higher Education Act, the scholarship benefit has been removed for all future awards. However, the current TQE grantees and scholarship recipients will still be required to submit these scholarship forms, but the overall burden will lessen as these extinguish.
I. Approximate Burden Hours for the TQE Scholarship Contractual Agreement
A.] Burden Hours to Institutions of Higher Education (IHEs) for the TQE Scholarship Contractual Agreement
It is anticipated that approximately five TQE IHEs will be awarding scholarship contractual agreements to approximately 25 prospective teachers in their efforts to improve teacher recruitment in high-need LEAs.
Recordkeeping: The 5 IHEs will be responsible for informing students about the requirements of the “teach or pay” provision and obtaining their signatures on a contractual agreement. It is estimated that it will take approximately 20 minutes to inform each student about the provisions and to obtain a signature.
Reporting: Once the IHEs have obtained student signatures on the TQE Scholarship Contracts, they are required to subsequently provide this information to ED concerning the recipients on a semi-annual basis. It is anticipated that it will take an additional one-half hour (30 minutes) semi-annually to transmit the required information to ED.
Burden for IHEs is estimated as follows:
Recordkeeping: 25 students x 1/3 hour = 8 hours
Reporting: Five postsecondary institutions x 30 minutes semi-annually (1 hour annually)
= 5 hours
Estimated Total Annual IHE Burden Hours for Contractual Agreement: 13 hours
B.] Burden Hours to Scholarship Recipients for the TQE Scholarship Contractual Agreement
It is anticipated that approximately 25 prospective teachers will be awarded scholarship contracts to fund their postsecondary education and prepare to serve as teachers in high-need LEAs and their respective schools.
Recordkeeping: When scholarship recipients receive their scholarship contractual agreements, they are required to read and sign their initial contracts, agreeing to the “teach or pay” provision of the program. It is estimated that it will take each student recipient approximately 20 minutes to fulfill this requirement.
Burden for Recipients of the Scholarship Contractual Agreement is estimated as follows:
Recordkeeping: 25 student recipients x 1/3 hour = 8 hours
Estimated Total Annual Recipient Burden Hours for Contractual Agreement: 8 hours
Estimated Total Annual Burden Hours for the TQE Scholarship Contractual Agreement Form: 13 IHE burden hours + 8 Recipient burden hours = 21 hours
II. Approximate Burden Hours for the TQE Scholarship Terms and Conditions Addendum
A.] Burden Institutions of Higher Education (IHEs) for the TQE Scholarship Terms and Conditions Addendum
It is anticipated that approximately five TQE IHEs will also be awarding scholarship terms and conditions addenda (to prior contracts) to approximately 215 prospective teachers, to continue their efforts to improve teacher recruitment in high-need LEAs.
Recordkeeping: The five IHEs will be responsible for informing students about the requirements of the “teach or pay” provision and obtaining their signatures on the terms and conditions addenda. It is estimated that it will take approximately 20 minutes to inform each student about the provisions and to obtain a signature.
Reporting: Once the IHEs have obtained student signatures on the TQE Scholarship Terms and Conditions Addenda, they are required to subsequently provide this information to ED concerning the recipients on a semi-annual basis. It is anticipated that it will take an additional one-half hour (30 minutes) semi-annually to transmit the required information to ED.
Burden for IHEs is estimated as follows:
Recordkeeping: 215 students x 1/3 hour = 72 hours
Reporting: 5 postsecondary institutions x 30 minutes semi-annually (1 hour annually) =
5 hours
Estimated Total Annual IHE Burden Hours for Scholarship Terms and Conditions
Addenda: 77 hours
B.] Burden Hours to Scholarship Recipients for the TQE Scholarship Terms and Conditions Addendum
It is estimated that approximately 215 prospective teachers will be awarded scholarship terms and conditions addenda, to continue to fund their postsecondary education and prepare to serve as teachers in high-need LEAs and their respective schools.
Recordkeeping: When scholarship recipients receive their terms and conditions addenda, they are required to read and sign these addenda (to earlier contracts), agreeing to the “teach or pay” provision of the program. It is estimated that it will take each student recipient approximately 20 minutes to fulfill this requirement.
Burden for Recipients of the Scholarship Terms and Conditions Addenda is estimated as follows:
Recordkeeping: 215 student recipients x 1/3 hour = 72 hours
Estimated Total Annual Recipient Burden Hours for Scholarship Terms and Conditions
Addenda: 72 hours
Estimated Total Annual Burden Hours for the TQE Scholarship Terms and Conditions Addendum: 77 IHE burden hours + 72 Recipient burden hours = 149 hours
III. Approximate Burden Hours for the Verification of Teaching Obligation Form
When TCT Scholarship recipients have completed their teacher training, they have six months in which to obtain employment with a high-need LEA. When they have done so, they are required to notify ED of their employment and have an LEA official certify annually that they are employed in a high-need school in a high-need LEA. Subsequently, the LEA must certify annually that the recipient has fulfilled the teaching obligation at the end of the school year (and return the form to the recipient).
A.] Burden Hours to Scholarship Recipients for the Verification of Teaching Obligation Form
It is anticipated that approximately 120 TQE scholarship recipients will need to complete the form to notify ED of their employment in a high-need LEA that they have after they have obtained within six months completing their teacher preparation education, funded by TQE Scholarships and the subsequent Terms and Conditions Addenda.
Recordkeeping: It is estimated that it will take the recipient approximately 30 minutes per year to read and sign the form and give it to an official in their LEA in which they are employed.
Reporting: It is estimated that it will take the recipient approximately 30 minutes per year to send their Verification of Teaching Obligation Forms to ED.
Burden for Recipients of the Verification of Teaching Obligation Form is estimated as follows:
Recordkeeping: 120 student recipients of Verification of Teaching Obligation Forms
x 1/2 hour = 60 hours
Reporting: 120 student recipients of Verification of Teaching Obligation Forms x 1/2
hour = 60 hours
Estimated Total Annual Recipient Burden Hours for Verification Form: 120 hours
B.] Burden Hours to LEAs for the Verification of Teaching Obligation Form
It is anticipated that approximately 40 LEAs are required to certify annually that each TQE scholarship recipient is currently employed in a high-need school and to subsequently confirm that the teacher remained employed for the expected period of time. For this purpose, each scholarship recipient will provide the Teaching Verification Form to the LEA for the signature of a certifying official. This is a two-part document, which has been designed to minimize the reporting burden on the LEA. It is estimated that it will take the LEA approximately 30 minutes (15 minutes to verify hiring and 15 minutes to verify continued employment) for each student teacher (recipient) to meet this requirement.
Note: These procedures and their resulting burden have been tailored to be as similar as possible to those successfully used by ED for the Perkins Loan Program and for other student assistance programs.
Burden for LEAs is estimated as follows:
Recordkeeping: 120 recipients x 1/2 hour = 60 hours
Estimated Total Annual LEA Burden Hours for the Verification Form: 60 hours
Estimated Total Annual Burden Hours for the Verification of Teaching Obligation Form:
120 Recipient burden hours + 60 LEA burden hours = 180 hours
Total Annual Number of Respondents: 410 respondents:
TQE Scholarship Contractual Agreement = 5 IHEs + 25 Recipients =
30 Respondents
TQE Scholarship Terms and Conditions Addendum = 5 IHEs + 215 Recipients =
220 Respondents
Verification of Teaching Obligation Form = 40 LEAs + 120 Recipients =
160 Respondents
Total Annual Number of Responses: 410 responses:
TQE Scholarship Contractual Agreement = 5 IHEs + 25 Recipients =
30 Responses
TQE Scholarship Terms and Conditions Addendum = 5 IHEs + 215 Recipients =
220 Responses
Verification of Teaching Obligation Form = 40 LEAs + 120 Recipients =
160 Responses
Total Annual Number of Burden Hours: 350 hours
(21 Scholarship Contractual Agreement hours + 149 Scholarship Terms and
Conditions Addenda hours + 180 Verification of Teaching Obligation Form hours)
The annual cost burden to respondents or record-keepers is estimated as follows:
Cost Burden for TQE Scholarship Contractual Agreement
Number of Respondents 5 IHEs
Number of Respondent Burden Hours 13 IHE Burden Hours
Cost to IHEs per Burden Hour (i.e., average
hourly salary) $45
Total Costs to IHEs for TQE Scholarship Contractual Agreement 13 Hours * $45 = $585
Total Burden Costs to Scholarship Recipients for TQE
Scholarship Contractual Agreement
(There is no monetary cost to scholarship recipients) $0
Estimated Total Burden Cost for TQE Scholarship Contractual
Agreement $585 + 0 = $585
Cost Burden for TQE Scholarship Terms and Conditions Addenda
Number of Respondents 5 IHEs
Number of Respondent Burden Hours 77 IHE Burden Hours
Cost to IHEs per Burden Hour (i.e., average
hourly salary) $45
Total Costs to IHEs for TQE Scholarship Terms and Conditions Addenda 77 Hours * $45 =
$3,465
Total Burden Costs to Scholarship Recipients for TQE Scholarship
Terms and Conditions Addenda
(There is no monetary cost to scholarship recipients) $0
Estimated Total Burden Cost for TQE Scholarship Terms and
Conditions Addenda $3,465 + 0 = $3,465
Cost Burden for Verification of Teaching Obligation Form (VTO)
Number of LEAs affected
40
(Note: It is expected that many students will
be concentrated in the high-need LEAs cited
in grant partnerships, since those LEAs will
actively recruit scholarship recipients.)
Estimated number of scholarship recipients who
will require certification of employment 120
Average time to process each certification form 30 minutes (.5 hours)
Total burden hours to process certification forms
(120 Recipients x .5 hours) 60 hours
Average salary per hour of LEA employees $40
Total Burden Cost to LEAs for VTO 60 hours * $40 = $2,400
Total Burden Cost to Scholarship Recipient s for VTO
(There is no monetary cost to scholarship recipients) $0
Estimated Total Burden Cost for VTOs $2,400 + $0 = $2,400
Estimated Total Annual Burden Cost for the TQE Scholarship Contractual Agreement +TQE Scholarship Terms and Conditions Addenda + TQE Verification of Teaching Obligation Form
$585 + $3,465 + $2,400 = $6,450
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.)
No other expenses are incurred other than those included in Item 12.
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.
The Annual Cost to the Federal Government is estimated as follows:
Professional staff to develop, package, and prepare clearance
package (GS-13 employee) 40 hours x $48.35 per hour $1,934
Professional staff to administer the record-keeping and
secure information provided by grantee
(GS-12 employee 50%)
$84,855 per year x 50% $42,428
Salaries Total Cost: $44,362
Overhead costs related to facilities, administration and
other indirect costs plus accrual of leave and fringe benefits;
estimated at 50% of salaries
$44,362 x 50% $22,181
Data Base (TSAR) Maintenance and On-Site Support -Contract for maintaining and processing of TQE scholarship applications/contracts, addenda, and verification of teaching obligation forms.
$63,296
Total Annual Cost Burden to Federal Government $66,543 + $63,296 =
$129,839
15. Explain the reasons for any program changes or adjustments reported in Item 16 of IC Form Part I.
This information collection requests an “adjustment” that results in a reduction in burden, from 2,850 responses to 410 responses; and from 3,065 hours to 350 hours. The primary reason for the reduction in burden is due to a reduction in the number of IHEs affected by this collection package (from 50 in the current collection to 5 in IHEs that award both scholarship contractual agreements and addenda to their respective students). The reason that fewer IHEs are awarding scholarships to students is that the majority of the IHEs that were affected by the scholarship collection package in 2008 have ended their grant performance period, and are no longer receiving funding by the U.S. Department of Education under the Teacher Quality Enhancement Grant Program (TQE), as authorized by the Higher Education Act (HEA) of 1965, as amended in 1998. Since the majority of IHEs that awarded TQE scholarships to students are no longer receiving TQE funds, they are no longer awarding TQE scholarship contractual agreements or the addenda to students.
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 results of the information collection will not be published.
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.
ED is not seeking this approval.
18. Explain each exception to the Certification statement from the “Certification for Paperwork Reduction Act Submissions.”
ED is not requesting any exceptions to the “Certification for Paperwork Reduction Act Submissions”.
B. Collection of Information Employing Statistical Methods
Not applicable to this collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Authorised User |
| File Modified | 0000-00-00 |
| File Created | 2021-02-01 |