SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
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.
Title II of the Workforce Investment Act (WIA -- P.L. 105-220), entitled the Adult Education and Family Literacy Act (AEFLA), creates a partnership among the Federal government, States, and localities to provide, on a voluntary basis, adult education and literacy services. Section 212 of Title II requires that a comprehensive performance accountability system be established to assess the effectiveness of eligible agencies in achieving continuous improvement of adult education and literacy activities in order to optimize the return on the Federal investment.
The accountability system is required to include the following core indicators or measures of performance:
demonstrated improvements in adult learners’ literacy skill levels;
placement in, retention in, or completion of postsecondary education, training, unsubsidized employment or career advancement; and
receipt of a secondary school diploma or its recognized equivalent.
States submit 11 required tables and 6 optional tables that are included in the document named “Instrument.” States include in their statistical reports all participants in programs:
that meet the purposes of AEFLA, and,
for whom expenditures are reported on the Financial Status Report.
States are to consider the performance of their grantee agencies on the measures as one factor in determining eligibility for funding (Section 224 (b)(3)). Section 212 (c) requires each eligible agency to report annually to the Secretary on the progress of achieving eligible agency performance measures, including information on the levels of performance achieved with respect to the core indicators of performance. The Secretary (Section 212 (c)(2)) is required to make the information contained in the State reports available to the public, disseminate State-by-State comparisons of the information, and provide the appropriate committees of Congress with such reports. In addition, the Secretary is to consider eligible agency performance on the core indicators of performance in awarding performance incentive grants to States (Section 503).
Two other legislative and regulatory statutes require the collection of this information requested for OMB paperwork reduction clearance: The Government Performance and Results Act (GPRA) of 1993, and The Education Department General Administrative Regulations (EDGAR).
The Government Performance and Results Act (GPRA) of 1993. The Government Performance and Results Act (GPRA) of 1993 required all Federal agencies to develop strategic plans to ensure that their agencies’ services were delivered efficiently and in a manner that best suits client needs and to develop indicators of performance to demonstrate their agency’s impact. The Office of Vocational and Adult Education’s (OVAE) approved GPRA indicators for the Division of Adult Education and Literacy include measures of performance for the adult education and literacy program that entail measuring improvements in students’ literacy levels and other outcomes measures. OVAE plans to obtain this information on student outcomes from the States’ accountability systems.
The Education Department General Administrative Regulations (EDGAR). In addition to the statutory requirements contained in the Adult Education and Family Literacy Act, EDGAR requires submission of performance reports not more frequently than quarterly or less frequently than annually (34 CFR 80.40). Those regulations also require the submission of financial status reports not more frequently than quarterly or less frequently than annually (34 CFR 80.41) from each State to monitor State use of funds according to WIA requirements for expenditures.
OMB approved the data collection required by AEFLA, described in the National Reporting System (NRS) Implementation Guidelines in 2009 (OMB 1830-0027). OVAE is requesting the continuation of this collection to incorporate the changes described below.
During the fall of 2009, OVAE’s Assistant Secretary conducted listening sessions across the country with students, staff, and stakeholders to discuss the future direction of adult education programs. These regional conversations yielded a great deal of useful information about the needs of the national adult education program and the role of the National Reporting System (NRS). Among several key issues important to all stakeholders, participants expressed a need to examine the current NRS performance measures and consider improvements for data collection and reporting.
OVAE synthesized the feedback received from the States and developed NRS papers discussing six key accountability issues and proposals to address them. The papers were the subject of a special NRS congress that was convened in August 2010 to solicit additional input from State representatives and other adult education stakeholders. The papers were revised after the congress to incorporate their comments. Another round of State review and comment was conducted to inform the final version of the papers and the proposed changes to the NRS.
The changes to NRS Tables 5, 5a, 6, and 7 are discussed in the document titled “Discussion of NRS Instrument Revisions.”
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.
OVAE will use the information in the current collection to fulfill three WIA requirements outlined in Sections 503, 243, 212, and, to ensure our compliance with the Government Performance and Results Act of 1993.
Section 503-
WIA authorizes Section 503 incentive awards for States that exceed their performance levels established in their State plans. ED will use the information reported to determine whether performance levels have been exceeded and determine each State’s eligibility for these awards.
Section 243-
WIA Section 243 requires ED to identify and provide technical assistance to States and evaluate the effectiveness of local programs. The information reported will be used to identify which States are failing to reach acceptable levels of performance and thereby may need technical assistance from ED to foster improvement in their service delivery system. It will also be used to identify high performing States to assist in evaluation efforts by permitting contrasts between those States and States performing more poorly.
Section 212-
The Department will use the information received from the current collection to fulfill the reporting requirements in Section 212(c)(2) of WIA and OVAE’s reporting requirements under GPRA. AEFLA sets reporting requirements for Title II that state that the Secretary of ED shall:
publish each State’s report on their performance indicators,
disseminate State-by-State comparisons of performance, and
report to the appropriate committees of the U.S. Congress on State performance.
In addition to the purposes above, OVAE has used the information collected for budget justification.
GPRA-
GPRA required all Federal agencies to develop strategic plans to ensure that their agencies’ services were delivered efficiently and in a manner that best suits client needs and to develop indicators of performance to demonstrate their agency’s impact. OVAE’s approved GPRA indicators for the Division of Adult Education and Literacy include measures of performance for the adult education and literacy program that entail measuring improvements in students’ literacy levels and other outcomes measures. OVAE plans to obtain this information on student outcomes from the States’ accountability systems.
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 given to using technology to reduce burden.
Over the past several years, States have developed individual student record systems using relational databases to track students and to meet reporting requirements within the States.
Technology continues to play a significant role in the collection of the measures from the States, significantly reducing the burden of data collection and analysis. States will prepare the statistical reporting information through their individual student record systems and submit this information electronically. To assist States in electronic reporting, OVAE created, in 2004, a web-based system for the reporting of statistical and financial data that is required for national program comparability and to ensure overall program accountability. This system automates the process by which States collect and compile the data and results in a paperless annual reporting system.
Furthermore, the electronic submission and compilation of this annual reporting of data greatly increases its accuracy. Rather than taking individual paper reports from each local program and manually compiling them into one State report, the web-based submission automatically compiles the data and eliminates any manual calculations at the State or Federal level. Lastly, the web-based reporting system allows States the ability to submit statistical, financial and narrative reports electronically, in an integrated, seamless fashion.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The information to be collected in the annual reports is not available from any other source and the collection of the information will not duplicate any existing data collection efforts.
5. If the collection of information impacts small businesses or other small entities (Item 8b of IC Data Part 2), describe any methods used to minimize burden.
No small organizations or small businesses are affected by this data 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.
There would be several important consequences of not collecting this information or collecting it less frequently. First, ED would be unable to meet the requirements of WIA for our annual report to Congress on the extent to which States met their agreed-upon performance levels, as required in Section 212(c)(2). The Department would also be in noncompliance of GPRA reporting requirements if this information could not be collected to develop a performance reports. In addition, the annual incentive awards described above will be based on this data. Less frequent collections will either make it necessary to grant these awards based on outdated data, or will make it impossibleto grant the incentive awards on an annual basis, as required by law.
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.
No special circumstances apply to this effort.
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.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
The respondents will not receive any payments or gifts for completing the information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The data collected by states and submitted to the US Department of Education will contain only aggregated data. Assurances of confidentiality to adult education participants are, therefore, not applicable to this data collection project.
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.
None of the data collected in the National Reporting System is sensitive in 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.
WIA
and EDGAR require eligible agencies to submit Annual Performance
Reports to demonstrate continuous improvement in the delivery of
their approved State Plan. The estimate below is based on a
combination of the experience of past years and information received
from selected State agencies. Information provided by the selected
State agencies showed a wide range of estimated burden hours. The
estimated burden hours for the 57 respondents range from 100 hours
per respondent (i.e. no increase) to 1,900 hours per respondent in
year one of the data collection. The wide variation in estimated
burden hours results from:
the great differences in size among the adult education programs sponsored under AEFLA,
the scope and range of complexity of the changes varies among states (several states already collect some elements of the proposed new data collections), and
many eligible agencies have full-time IT personnel assigned to adult education that will perform any software revisions as routine work with no additional cost, whereas some States use outside contractors to support their IT efforts that reflect additional burden hours and cost.
The estimated average burden hours are 750 hours per response in the first year (2012-2013) for a total estimate of 42,750 burden hours. In years two and three of data collection, the estimated average burden hours are 100 hours for each of the 57 respondents for a total of 5,700.
Program Year |
Number of Responses |
Type of Staff |
Average Burden Hours per Response |
Total Average Burden Hours for All Responses |
2012-13 |
57 |
Professional Data Entry Computer |
200 40 510 = 750 hours |
11,400 2,280 29,070 =42,750 hours |
2013-14 |
57 |
Professional Data Entry
|
80 20 =100 hours |
4560 1140 =5700 hours |
2014-15 |
57 |
Professional Data Entry
|
80 20 =100 hours |
4560 1140 =5700 hours |
The three-year average number of burden hours is 18,050 and is obtained by averaging the burden hours over the three-year period. This calculation is shown in the table below.
Three-Year Average Burden Hours Per Response |
Three-Year Average Burden Hours For All Responses |
750 hours in year one +100 hours in year two +100 hours in year three 950 (hours) ÷ 3 (years) = 317 hours |
42,750 hours in year one +5,700 hours in year two +5,700 hours in year three 54,150 (hours) ÷ 3 (years) = 18,050 hours |
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 16 of IC Data Part 1.
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.
In the first year of implementation, the estimated average one-time annual cost is $23,170 per response to revise, test, and provide training on State data systems. This estimate is based on 200 hours for professional staff at $24.00 per hour, 40 hours for data entry clerks at $13.00 per hour, and 510 hours for computer programmers at $35.00 per hour. In years two and three, the annual estimated cost to each respondent is approximately $2,180. Using an average preparation time of 100 hours per response, 80 hours would be used for professional review, research, and gathering information. The remaining 20 hours would be used for data entry.
Program Year |
Type of Staff |
Average Burden Hours per Response |
Hourly Rate |
Average Total Cost Per Response |
2012-13 |
Professional Data Entry Computer |
200 + 40 + 510 750 hours |
$24 $13 $35
|
$4,800 $520 $17,850 $23,170 |
2013-14 |
Professional Data Entry
|
+ 80 + 20 100 hours |
$24 $13
|
$1,920 $ 260 $2,180 |
2014-15 |
Professional Data Entry
|
+ 80 + 20 100 hours |
$24 $13
|
$1,920 $ 260 $2,180 |
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 acquiring and maintaining 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 : 0
Total Annual Costs (O&M) : 0
____________________
Total Annualized Costs Requested : 0
The total for the capital and start-up cost components for this information collection is zero. The information collection will not require the purchase of any capital equipment nor create any start-up costs. Computers and software used to complete this information collection are part of the respondents' customary and usual business or private practices, and therefore is not included in this estimate.
The total operation and maintenance and purchase of service components for this information is zero. The information collection will not create costs associated with generating, maintaining, and disclosing or providing the information that is not already identified in question 12 of this supporting statement.
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.
One-Time Federal Software Modifications
There are one-time costs to updating the Federal data system through which states report the data. The total cost is estimated at $115,939 for software revisions and testing.
Program Office Staff
The total estimated Federal cost for program office staff is $126,470.40 over three years and is calculated as follows:
Program Office Staff |
Estimated Number of Hours Per Year |
FY 2011 Hourly Rate |
Estimated Cost Per Year |
Total Cost for Three Years |
GS-12 GS-13 GS-14 |
440 240 320
|
$35.88 $42.66 $50.41
|
$15,787.20 +$10,238.40 +$16,131.20 $42,156.80 |
$47,361.60 +$30,715.20 +$48,393.60 $126,470.40 |
The total Federal costs are estimated to be $242,409.40 over three years, with an average annual cost of $80,803.13. This includes contractor beta testing and web site maintenance, and the salaries and expenses of program staff who manage the process. The average annual Federal cost is calculated as follows:
$115,939 Software Modification Costs
+ $126,470.40 Federal Program Office Staff Costs
$242,409.40 Total Federal Costs for Three Years
÷ 3 Divided by 3 Years
= $80,803.13 Average Annual Federal Costs
15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.
A one-time increase in burden is anticipated to implement the following changes by July 1, 2012. Adult education grantees will designate reporting cohorts based on certain learner criteria and collect new data on teacher experience, teacher certification, and student years of schooling. The current OMB approved annual inventory is 6,840. The requested average annual burden hours are 18,050. The difference in burden hours is 11,210 (650 per respondent) is due to program changes and allows States to develop and implement these modifications effectively.
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.
There are no plans for publication of data 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.
OVAE is not seeking exemption from displaying the expiration date.
18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.
This request is in compliance with 5 CFR 1320.9.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | Kenneth Smith |
| Last Modified By | James Hyler |
| File Modified | 2011-06-20 |
| File Created | 2011-06-20 |