Ss-1855-0new(4445)

Supporting Statement for the Information Collection Request for the Charter School
Authorizer Annual Update administered by the National Charter School Resource Center,
Charter Schools Program, Office of Innovation and Improvement
October 15th, 2010
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.
The U.S. Department of Education (ED) has as one of its important policy goals expanding the
number of high-quality public school choice options. Specifically, according to Part B section
5201 of the Elementary and Secondary Education Act, two of the established purposes of the
Charter School Program office are: evaluating the effects of charter schools, including the effects
on students, student academic achievement, staff and parents, and expanding the number of highquality charter schools available to students across the nation.
Charter school authorization is at the very crux of any efforts to expand and ensure high-quality
public school choice options through public charter schools because charter school authorizers
are the public entities primarily responsible for: initial charter authorizations, on-going
monitoring and oversight, and charter renewal and closure decisions.
Currently, there is no comprehensive national database of the roughly 900 charter school
authorizers complete with the schools under their authority; some of these data elements are
available from public documents, but they are not made available to the public consistently
across all authorizers. There is also no comprehensive, fully-populated tool for tracking the
activities of and evaluating the quality of authorizers nationwide based on their authorizing
decisions in light of schools’ performance. This survey will be administered across the entire
universe of charter school authorizers.
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 National Charter School Resource Center (Charter School Center) will be administering the
necessary survey, collecting the resulting information, and establishing the national authorizer
database. The Charter School Center is contracted by the US Department of Education’s Office
of Charter Schools to provide resources and information to the public and charter school
stakeholders in pursuit of the Charter School Program’s statutory mission. Charter School
Center staff at Learning Point Associates and research partners from Public Impact will collect
data from all of the nation’s charter authorizers. The data will focus on their respective schools
1

and fall within the following general categories: characteristics of schools under their authority,
renewal/closure cycles and decisions, related reasons for renewal or closure, and other
information around authorizers’ renewal, closure, and interim policies and practices.
These data will be collected annually via on-line surveys (highly preferable) and paper surveys.
The on-line survey link will be provided to respondents via e-mail correspondence and on the
mailed paper survey.
The purpose of this project is for the Charter School Center to build, maintain and implement a
publicly available charter school authorizer database that aligns authorizer data with individual
charter school data. This database will enable policymakers, educators, researchers, and the
public to know at a glance all historic and upcoming authorizer decisions. It will also enable
these audiences to better understand whether individual authorizers are making charter renewal
and closure decisions connected to the academic performance of schools as indicated by an
Academic Charter School Quality Indicator which is currently under development through a
separate ED contract.
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 information collection will be administered with both a paper survey instrument mailed to
respondents and electronic completion and submission via the Charter School Center website at
www.charterschoolcenter.org. The paper survey instrument will include instructions on how to
access and complete the electronic version of the survey. Electronic completion and submission
will greatly reduce the recordkeeping and data entry burden, so this method will be encouraged.
However, expert input from a Charter School Center advisory board member indicated that
mailing the paper survey to respondents served several purposes: 1) it serves as a physical
reminder that the survey needs to be completed; 2) it serves as an organization tool on which
respondents can gather all of the necessary information before entering it into the online version;
3) for the percentage of respondents that are not able or do not wish to complete the survey
electronically, it provides another way to collect the information.
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.
There is no comprehensive national database of the roughly 900 charter school authorizers
complete with the schools under their authority currently in existence. Also, there is currently no
comprehensive, fully-populated tool for evaluating the quality of authorizers nationwide based
on their authorizing decisions in light of schools’ performance. The National Association of
2

Charter Authorizers (NACSA) will provide the Charter School Center with the list of
approximately 900 authorizers and the charter schools that they authorize, which avoids
duplication of effort around basic data collection for those authorizers and their schools.
Support staff will follow up with non-respondents six weeks after survey administration by
phone or email and encourage potential respondents to complete the survey electronically or, in
some cases, by phone.
The survey instrument was tested on six potential respondents in early October 2010. These
respondents provided feedback on ease of completion and question comprehension, and feedback
was incorporated into the final survey instrument.

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.
Many charter school authorizers are local school districts, and so range in size from small to very
large. Authorizers are also State Educational Agencies, universities, and other non-profits and
governmental organizations. As a rule, smaller entities generally authorize fewer schools,
making the amount of information collected proportionate to the authorizer’s size. Moreover,
the information collection represents a very minimal burden to each authorizer (0.5 to 4.0 hours
annually depending on the number of schools authorized). The requested information is intrinsic
to an authorizer’s operations and should be readily available to these 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.
As stated above, The U.S. Department of Education has as one of its important policy goals
expanding the number high-quality public school choice options. Specifically, the Charter
School Program office within the Office of Innovation and Improvement is at the forefront of
efforts to achieve this goal.
Charter school authorization is inherently a critical component of successfully doing so because
these are the state and local bodies that have the authority to grant, monitor, oversee, renew and
close public charter schools. Thus, a means for stakeholders to be able to access objective
information about authorizers based on their decision-making in light of the performance of
schools under their charge is essential to achieving the high-quality public school choice goals of
the U.S. Department of Education. If this information is not collected, it would be extremely
difficult, if not impossible, for stakeholders to access and utilize this information on a national
scale.

3

7. 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.
There are no special circumstances that require the information collection to be conducted in any
of the manners described 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.
The survey published a 60-and 30-day Federal Register Notice; during the 60-day Federal
Register published on November 16, 2010 in volume 75 page 69425 OII received two public
comments. Submitted comments included requests to add additional data elements to the survey,
specifically to provide more information on the charter schools identified. Changes to the survey
instrument were not made based on these comments. Adding additional data elements would
4

significantly increase the burden on authorizers completing the survey, lower the survey
completion rate, and are not necessary to determine initial charter authorizations, on-going
monitoring and oversight, and charter renewal and closure decisions. One comment suggested
the addition of a question regarding how many charter applications the authorizer has received
since 2005; with OII concurrence this question was added to the instrument. The definition of
“alternative” was changed to delete the reference to students on an Individualized Education
Program (IEP).
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.
The Charter School Center consulted with charter school authorizers as well as representatives
from the National Association of Charter School Authorizers (NACSA). Specifically, draft
surveys were disseminated to a small sample of charter authorizers and NACSA staff to yield
feedback on structure, clarity, user-friendliness and potential for high return rates. Several
revisions were made to the survey instrument in light of the feedback gained through the process.

9. Explain any decision to provide any payment or gift to respondents, other than
renumeration of contractors or grantees.
No gifts or payments will be made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulations, or agency policy.
No assurance of confidentiality is provided as the information is public.
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. 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.
No questions in this information collection are of a sensitive nature.
5

12. Provide estimates of the hour burden of the collection of information.
! 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.
This information request covers one form.
Number of respondents (estimated)
Frequency of response
Annual hour burden

900
once annually
2.25 hours on average, depending on number
of charter schools authorized (more schools
will increase the burden) and ease of
authorizer record retrieval. (Expected range
of burden is 0.5 to 4 hours per authorizer.)
This burden was estimated based on the
length of the survey and consultation with
individuals who are familiar with authorizing
practices, to determine approximate survey
completion time.
$35 per hour
$78.75 per respondent, on average
$70,875 across all respondents annually

How was this burden estimated?

Annual cost to respondents

This amount is expected to be reduced by
50% after the first year, as the incremental
information needed will be considerably less.

6

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.
There is no capital, start-up, or maintenance cost to respondents.
a) For the Charter School Center, (who will hold and maintain the database) start-up cost of
the database is estimated at $85,000 in the first year. To accomplish database construction,
the Charter School Center estimates a total of 1,159 hours are needed from two
information technology support staff. These staff hours comprise the total start-up cost of
developing the database infrastructure.

b) The approximate cost of on-going annual maintenance and data collection is $65,000 per
year.
This cost is comprised of:
1,166 staff hours

$62,000
7

Supplies (for administering paper survey)
Total

$3,000
$65,000

Therefore the total cost of information collection is:
First year
Second year
Third year
Fourth year
Fifth year

$85,000 + $65,000 = $150,000.
$65,000
$65,000
$65,000
$65,000

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.
Additional cost to the Federal government, excluding Item 13, is $0

Aggregate cost estimate from Items 12, 13, and 14
12. Cost to respondents, year 1
$70,875
13. Total annual cost burden, year 1
$150,000
14. Cost to the Federal government
$0

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14
of the OMB Form 83-I.
This is a new program, so there are no changes or adjustments.
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 information will be published via a searchable database available at
www.charterschoolcenter.org. No complex analytical techniques or statistical methods will be
used.

8

Year 1 Schedule
Task
Survey development and submission to OMB
Survey administration
Data collection and entry
Database published

Completion date
October 2010
March or April 2011
April – July 2011
August 2011

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 expiration date will be displayed on the information collection.
18. Explain each exception to the certification statement identified in Item 20,
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
There is no exception to the certifications.

9