ICRAS Tracking and OMB Number: (1463.03) 1845-0099 v2 Revised: 1/28/2013
RIN Number: XXXX-XXXX (if applicable)
SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
General Provisions – Financial Assistance for Students with Intellectual Disabilities
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, or you may provide a valid URL link or paste the applicable section1. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change). If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.
As provided by the Higher Education Act of 1965, as amended, (HEA) these regulations allow students with intellectual disabilities, who enroll in an eligible comprehensive transition and postsecondary program to receive Title IV, HEA program assistance under the Federal Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), and Federal Work Study (FWS) programs (see sections 484(s) and 760 of the HEA).
This request is for renewal of the current recordkeeping requirements contained in the regulations at 34 CFR 668.232 and 668.233 related to the administrative requirement of the financial assistance for students with intellectual disabilities program. The information collection requirements are necessary to determine the eligibility to receive program benefits and to prevent fraud and abuse of the program funds.
Section 668.232 – Program eligibility
The regulations create procedures outlining how to apply to the Secretary for, and determine the eligibility of, an institution’s comprehensive transition and postsecondary program for students with intellectual disabilities be added to the list of eligible programs offered.
Section 668.233 – Student eligibility
The regulations identify how a student with intellectual disabilities could qualify for the benefit and include the general types of information that must be collected to evidence the intellectual disability.
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 institution will obtain a record from a local education agency or other specified documentation to determine that the student with intellectual disabilities is eligible to participate in the Federal Pell Grant, FSEOG, and FWS programs. The institution will also have to apply to the Department for approval of, or a waiver of, its comprehensive transition and postsecondary program which will be a combination of electronic application and other documentation from the school.
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.
In applying for eligibility of its comprehensive transition and postsecondary program for students with intellectual disabilities, institutions will use a combination of electronic applications and paper documentation.
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.
There is no duplication of data as a result of the collection of this information.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less than 50,000.
No small businesses are impacted 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.
Per regulation the information must be collected whenever an institution wishes to apply to participate.
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.
The information collection requirements require no special circumstances.
As applicable, state that the Department has published the 60 and 30 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.
This is the 30 day comment period for this collection package to solicit comments on the current burden assigned to these regulations. To date no comments have been received regarding this current information request.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.
No payments or gifts will be provided to the respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided.2 If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data.
These requirements do not cover any confidential information.
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 of Education is not requesting any sensitive data.
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 in the ROCIS IC Burden Analysis Table. (The table should at minimum include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)
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.
As of July 1, 2012 there are 14 institutions that have applied for and been approved to offer financial aid through comprehensive transition and postsecondary (CPT) programs for students with intellectual disabilities. We are estimating additional participation in the CPT programs to total 25 institutions. This is a decrease from the initial estimation of participation with the first information collection filing in 2009.
668.232 – Program Eligibility
# of #of # of Hours
Respondents Responses Burden
Institutions
Public 20 20 x .33 hours = 7 hours
Private 5 5 x .33 hours = 2 hours
Subtotal 25 25 9 hours
This is a net decrease of 57 hours of burden from the prior information collection.
As of July 1, 2012 there are 36 eligible students at 12 approved institutions that have received financial aid through comprehensive transition and postsecondary (CPT) programs for students with intellectual disabilities. The institutions have met the information collection to determine student eligibility by contact with the local education authority (LEA) or other qualified professionals. We are estimating additional student participation in the CPT programs to total 50. This is a decrease from the initial estimation of participation with the first information collection filing in 2009.
668.232 – Student Eligibility
# of #of # of Hours
Respondents Responses Burden
Institutions
Public – LEA contact 34 x .25 hours = 9 hours
Public – Other qualified professional 6 x .75 hours = 5 hours
Subtotal - Public 20 40 14 hours
Institutions
Private – LEA contact 9 x .25 hours = 2 hours
Private – Other qualified professional 1 x .75 hours = 1 hour
Subtotal - Private 5 10 3 hours
TOTAL 25 75 17 hours
This is a net decrease of 751 hours of burden from the prior information collection.
# of #of # of Hours
Respondents Responses Burden
Current burden 400 2,560 834
Estimated new burden 25 75 26
Decrease in burden -375 -2,485 -808
We estimate that the cost to the institutional respondents will be:
# of Est. $ per Est. $
Responses Response Burden
Institutions
Public 20 x $24.61 x 1.33 hours = $655
Private 5 x $24.61 x 1.33 hours = $164
Subtotal 25 $819
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. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12
Total Annualized Capital/Startup Cost :
____________________
Total Annualized Costs Requested :
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.
There are no additional costs to the Federal government as a result of the final regulations.
15. Explain the reasons for any program changes or adjustments. Generally, adjustments in burden result from re-estimating burden and/or from economic phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours, responses and costs (if applicable).
The Department of Education is requesting an extension of the current collection while noting the adjustment through the decrease in the new estimated burden due to the smaller than anticipated participation in the CPT program. There has been no change in the requirements of the regulations. With this adjustment in responses we are correcting an overstated participation in the program.
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 this 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.
The Department is not seeking this approval.
18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.
The Department is not requesting any exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form. 83-1.
1 Please limit pasted text to no longer than 3 paragraphs.
2 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT |
| Author | Kenneth Smith |
| File Modified | 0000-00-00 |
| File Created | 2021-01-30 |