Att_30 Day Comment Period Supporting Statement for TS APR (revised 6-26-12)

EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

Annual Performance Report for Grants under the

Talent Search Program

Supporting Statement for Request for Approval under the Paperwork Reduction Act
and 5 CFR 1320

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 hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Department of Education (Department) is requesting approval of a new Talent Search (TS) Annual Performance Report (APR) form to collect annual performance data from projects funded by Talent Search (TS) program grants. This APR reflects new TS program regulations enacted on Oct. 26, 2010. The new regulations were necessitated by changes to the TS program in the Higher Education Opportunity Act (HEOA) of 2008. FY 2011-2012 is the first year of a five year grant cycle during which TS projects are required to adhere to the new regulations.

The TS program provides Federal financial assistance in the form of discretionary grants to: (a) institutions of higher education; (b) public and private agencies and organizations including community-based organizations with experience in serving disadvantaged youth;(c) secondary schools; (d) combinations of such institutions, agencies and organizations. The specific goal of the TS program is to help youth from disadvantaged backgrounds complete secondary education and enroll in and complete programs of postsecondary education; and to publicize the availability of, and facilitate the application for, student financial assistance for persons who seek to pursue postsecondary education (20 U.S.C. 1070a­­–12).

The information that grantees submit in the APR allows the Department to annually assess each grantee's progress in meeting their project's approved goals and objectives. The APR data are compared with the project’s approved objectives to determine the project’s accomplishments, to make decisions regarding whether funding should be continued, and to award prior experience points. The regulations for this program provides for awarding up to 15 points for prior experience (34 CR 643.22). During a competition for new grant awards, the prior experience points are added to the average of the field reader scores to arrive at a total score for each application. Funding recommendations and decisions are primarily based on the rank order of applications on the slate; therefore, assessment of prior experience points, based on data in the annual performance report, is a crucial part of the overall application process.

Further, this performance report form is the main source of data for the Department's response to the requirements of the Government Performance and Results Act (GPRA) for this program.

The Department collects information from TS grantees under the authority of Title IV, Part A, Subpart 2, Division 1, Sections 402A 402B of the Higher Education Act of 1965, as amended, the program regulations in 34 CFR 643, and the Education Department General Administrative Regulations (EDGAR), in 34 CFR 74.51, 75.720, and 75.732. Attached is a copy of the authorizing statute, as amended in 2008 by the Higher Education Opportunity Act, which is the basis for the current program regulations, also attached.

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 Department uses the data collected to (a) evaluate projects' accomplishments; (b) determine the number of prior experience points to be awarded to current grantees; and (c) aid in compliance monitoring (i.e., to determine whether grantees are in compliance with the selection requirements for project participants [34 CFR 643.3]).

In addition, the Department uses the annual performance reports to produce program-level data for annual reporting, budget submissions to OMB, Congressional hearings and inquiries, and responding to inquiries from higher education interest groups and the general public.

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.

The data collection method allows the grantees to use computerized data systems to collect, retrieve, and report the requested information. A Web-based software application has been developed for grantees to enter the data online and submit the entire report via the Internet. The TS projects have been submitting the annual performance report via the Internet since 1998.

The data collected are in aggregate form at the program level, not data on individual participants; thus the reports are a low-level security risk. Nonetheless, the Web site is secured to ensure that the data are seen only by authorized individuals and are protected from network hackers. Further, online data edits are in place to ensure the accuracy and integrity of the data submitted.

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.

Since the information grantees submit in their performance reports is unique to each project and is not collected elsewhere, no duplication exists. No other instrument is available to collect the information that the program needs to assess prior experience or program outcomes. The data collected in the annual performance reports are fundamental to these programs.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This information collection does not affect 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.

The collection of performance reports is required annually. Collection of information on a less frequent basis is not feasible. These reports are used to determine if the grantee is making satisfactory progress in meeting the goals and objectives proposed in its initial grant application. In addition, the information is needed to award prior experience points to grantees. Without this data collection, the Department would not have the data to assess the prior experience provision of the authorizing statute, respond to the GPRA and other program performance and efficiency measures, or develop improved policies for program administration.

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.

This information collection is conducted in a manner consistent with 5 CFR 1320.5(d)(2).

8. As applicable, state that the Department has published the 60 day and 30 day Federal Register notices as 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.

On March 16, 2012, the Department of Education published a Notice of Proposed Information Collection Request in the Federal Register inviting comments on the proposed APR by May 15, 2012. Thirty eight respondents submitted approximately 300 individual comments (i.e., multiple comments from respondents). A copy of this Notice is included with this collection. Also included is a document which provides summaries and analysis of the comments, and indicates where changes were made to the APR in response to these comments. The Department will also be publishing a 30-day Federal Register Notice inviting final comments.

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

The Department will not provide payment or gifts to respondents.

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

No assurances of confidentiality are provided to the respondents.

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 performance report form does not include questions about sexual behavior and attitudes, religious beliefs, or other matters that are commonly considered sensitive and private.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents by affected public type (federal government, individuals or households, private sector – businesses or other for-profit, private sector – not-for-profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. 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.

• 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.

Estimated burden hour for this collection of information is 7,376. We estimate approximately 461 respondents. The performance reports are submitted annually.

	Number of Respondents	Estimated Preparation Time, per respondent	Total estimated burden hours
Public Sector	330	16 hours	5,280 hours
Private Sector	131	16 hours	2,096 hours
Total estimated burden hours	461	16 hours	7,376 hours

(Estimated burden: 7,376 hrs. Total number of hours (preparation time) multiplied by the total number of respondents equals estimated burden hours). Preparation time includes 14 hours for professional staff to gather the information using computerized technology and 2 hours for clerical staff to enter the data into the Web-based form.

Professional staff

(461 respondents X 14 hours X $35 per hour) $225,890

Clerical staff

(461 clerical staff members X 2 hours X $18 per hour) $16,596

Total estimated cost to all respondents $242,486

Note: As many of the respondents are project staff whose salaries are largely financed with Federal grant funds, the Department believes that the actual cost to respondents is lower than those indicated above but cannot provide an accurate estimate at this time.

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.

There are no other costs to the respondents associated with this information collection. Grantees are required by program regulations to collect and maintain this information. The costs to transmit the data electronically via the Web are 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.

The largest portion of the Government's cost is borne directly by the Department of Education in designing the report form, securing clearance of the form, and collecting, aggregating, and disseminating the information.

Designing performance report form 120 hours at $40 per hour Overhead (est. at 50%): 120 times $20	$7,200
Clearing performance report form
Clearing performance report 120 hours at $40 per hour Overhead (est. at 50%): 120 times $20	$7,200
Annual updates to Web application, Web site hosting, help desk, and data processing (contractor’s costs)	$80,000
Analyses of data and preparation of national summary reports and individual project data (contractor’s costs)	$90,000
Professional staff to review and edit reports for dissemination 160 hours at $40 per hour Overhead (est. at 50%): 160 times $20	$9,600
TOTAL FEDERAL COST	$194,000

15. Explain the reasons for any program changes or adjustments.

In previous years, the same APR form was used for both the TS and Educational Opportunity Centers (EOC) programs, because of similarities in the performance data collected for these two programs. However, statutory changes to the TS program resulting from the Higher Education Opportunity Act of 2008 (HEOA) and subsequent new regulations require the Department to collect substantially different data for each of these programs. Therefore, the Department is developing separate APR forms for TS and EOC. This form will only be used to collect data on TS participants. The new TS regulations increase grantee data collection and reporting requirements. Additionally, the final regulatory amendments to recordkeeping requirements require that a TS grantee document the services a student, who is served by more than one TRIO or other federally funded program, is receiving from another program during the project year. These two changes result in an increase in burden hours per grantee.

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.

Collected information will be analyzed annually to determine if each grantee is meeting its approved goals and objectives and to award prior experience points. Program performance and efficiency measures, based on data conveyed in grantees' annual performance reports, are disseminated in the Department's Annual Program Performance Plan. In addition, the Department's Web site provides data on performance and efficiency measures, beginning with the 2007–08 performance period, at the grantee level; this more detailed reporting has been made possible due to improvements in accuracy resulting from incorporating the standard objectives into the report form.

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.

This report form and the Web site will display the expiration date for OMB's approval of the information collection.

18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

There are no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

34 CFR 643.22(d)(6) of the TS program regulations require TS grantees to track postsecondary enrollees’ postsecondary attainment status over the course of six years as part of the Postsecondary Attainment objective. TS projects may either track all postsecondary enrollees or a random sample of them, as outlined in “Appendix: Guidance on Determining Appropriate Sample Size and Random Sampling to Track Students for Postsecondary Attainment Objective” in the TS APR Instructions.

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