2013 1830-0029 Perkins Supporting Statement - clean final

OMB #1830-0029

SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL UNDER THE PAPERWORK REDUCTION ACT

A. JUSTIFICATION

1. Circumstances necessitating information collection.

The Carl D. Perkins Career and Technical Education Act of 2006 (Perkins IV), 20 U.S.C. 2301 et seq. as amended by P.L. 109-270, was signed into law on August 12, 2006. The purpose of this request is to update the information collection package 1830-0029 (The Carl D. Perkins Vocational and Technical Education Act of 1998; P.L 105-332 – State Plan) to include: To provide an extension of the application submission requirements for years 2013-16 or until such time as a reauthorized or new statute replaces the current statute under which States are implementing programs and to add instructions on periodic reporting of States’ progress toward meeting performance levels for those States for which the Secretary imposes this condition on their grants.

Prior submission approvals:

• Instructions on application submission requirements for years 2010-2012 (the remaining years of the legislative authorization for the program)

• Instructions regarding contents of a one-year transition plan or six-year State plan;

• New State plan narrative requirements from the new Act;

• Information States must provide regarding the consolidation of Title II funds under Title I;

• Budget information;

• Accountability information; and

• A cover page that must be submitted with the State plan.

Perkins IV reauthorizes programs previously authorized by the Carl D. Perkins Vocational and Technical Education Act of 1998 for fiscal years 2007 through 2012. Title I of Perkins IV authorizes grants to eligible agencies in the fifty States, the District of Columbia, Puerto Rico, the United States Virgin Islands, and Guam for the purposes of “promoting the development of services and activities that integrate rigorous and challenging academic and career and technical instruction, and that link secondary education and postsecondary education” for participating career and technical education students. Grant amounts are determined by a formula prescribed in the law. Title II of Perkins IV authorizes grants to the same eligible agencies listed above to support tech-prep education programs as defined by Title II. Grant amounts are determined by the same formula used to allocate funds for Title I. Under section 202 of the Act, eligible agencies now have the option of consolidating all or a portion of their Title II funds under Title I.

Section 122 of the Act requires eligible agencies to submit a six-year state plan in order to receive funds under Title I. Section 201 requires eligible agencies to submit an application for Title II funds as part of its six-year state plan. These State plans were submitted April 2, 2007. The Act contains specific requirements for what must be included in the State plan. This collection is limited to the information that is required by Perkins IV, the General Education Provisions Act and its implementing regulations, and the Education Department General Administrative Regulations (34CFR Part 76.104). Unified Plan under the Workforce Investment Act

Section 501 of WIA provides eligible agencies with the option of submitting the State plan for Perkins IV as part of a unified plan that incorporates one or more related education and workforce development programs. These programs include employment-training activities authorized by Title I of WIA, the Adult Education and Family Literacy Act, programs authorized by Title I of the Rehabilitation Act, and work programs authorized under the Food Stamp Act. The portion of the unified plan that addresses career and technical education must meet all of the requirements for a State plan under Perkins IV. The Department will issue under separate cover guidance for States for submitting a unified State plan.

2. Use for which the information is gathered.

Staff members of the Division of Academic and Technical Education, Office of Vocational and Adult Education review the State plans to determine compliance with the Act, as required by section 122 of the Act. The State plans also are used as a source of information for policy analysis and for responding to inquiries from members of Congress and others. States cannot receive Federal career and technical education funds without the submission and approval of the State plans. State Plan revisions submitted in subsequent years will be used in the same manner as described above.

3. Use of improved information technology.

The Department is encouraging eligible agencies to submit State plans electronically. Last year, all States submitted electronically their required State plan revisions; therefore, we anticipate that every eligible agency make an electronic submission of their new State plan. All States are now submitting electronically.

4. Efforts to identify duplication.

Prior legislative State plans expired March 31, 2007. They were developed, submitted, and approved under the Carl D. Perkins Vocational and Technical Education Act of 1998, which was repealed by P.L. 109-270, effective August 12, 2006. The new Act contains additional and more rigorous requirements for the submission of State plans that must be addressed in the new State plans. There are no similar data collections which gather this information.

5. Small businesses.

This collection does not impact small businesses.

6. Consequence of less frequent collection.

The State plan serves as the basis for the granting of Federal career and technical education funds under the Act. The Department of Education could not release funds to the States if the information collection was not conducted. The Act dictates the frequency of collection and the types of information that must be collected.

7. Special circumstances.

No such circumstances exist.

8. Federal Register notice/consultation outside the agency.

Time since enactment of the Act has not permitted consultation with eligible agencies prior to submission of this request. In early October 2012, we convened a meeting here in Washington, DC, of all the State Directors of Career and Technical Education to discuss the new provisions of the Act, including the new requirements concerning State plans. Since that time ongoing consultation is achieved through monthly conference calls with the State Directors on a quarterly basis. A 60-and-30-day FRN was published with no public comments.

9. Payments of gifts to respondents.

We will not provide gifts or payment to respondents. The submission of a State plan is a prerequisite for eligible agencies to receive funds.

10. Assurance of confidentiality.

No pledges or assurances of confidentiality are made to respondents.

11. Questions of a sensitive nature.

There are no questions of a sensitive nature.

12. Estimate of respondent burden.

The development of the initial information collection package that permitted states to submit a one-year transition State plan, a five-year State plan or a six-year State plan was the product of extensive consultation with eligible agencies. The time required to develop state plans under the previously approved collection lead us to estimate that the development and submission of the information collected pursuant to Title I and Title II of the Act for submission of either a six-year or five-year State plan required an estimated average of 7,560 hours of professional staff time to gather, compile, review and prepare information and 1,620 hours of clerical staff time.

This collection (2013-2016) will distribute the burden equally from year to year – prior collections were calculated on an alternating year of negotiation for performance levels for 2 years. From this point on, in each year, States will negotiate performance levels for the upcoming year of collection, rather than doing so in alternating years. The chart (enclosed) reflects distribution of the burden hours for the requested extension years. However, the annual burden will decrease because States no longer receive funding under Title II of Perkins IV (Tech Prep Education Grants) and will not submit paperwork related to Title II grants.

Additionally, due to the need for the Secretary to monitor States that have failed to meet at least 90% of a particular performance level in their State plans, this collection is experiencing a resulting requirement for such States to provide periodic reports on their progress toward meeting their performance levels and implementing improvement plans. In previous years, the Secretary has required such periodic reports from no more than nine States but anticipates that this number may increase above nine in the next three years. (The Secretary cannot estimate the number of respondents that will be required to file status reports in the next three year – theoretically it could be from 0 to 56 respondents – because this requirement will be based on a State’s actual performance with respect to each performance level over a three-year period.) In order to ensure that the Secretary can monitor States’ progress in meeting their levels and provide necessary technical assistance, this collection will now allow the Secretary to require periodic reporting from States as to their progress toward meeting the performance levels and implementing improvement plans where a State has missed the 90% mark for a particular performance level for three or more consecutive years. This reporting will be minimal in that it will require States to provide a status report (via email) of their progress.

With respect to States that do not miss a particular performance level for 3 or more years, the overall burden will decrease slightly during the next three years due to the discontinuation of funding for Title II. While those States that miss the 90%-mark will have a slight increase in the burden as a result of the periodic reports, it was determined that the burden is minimal (less than one hour per report) and is more than offset by a reduction in burden as it relates to the elimination of Title II requirements as of 2011 (which is the first year that Title II was not funded).

The total estimated annual average cost over the three (3) program-year periods (i.e. 2013 to

2016) is $46,740 for 56 respondents. (This remains the same for the requested extension period although the actual burden will be slightly less for States that do not submit periodic reports.) This figure represents, for all 56 respondents, the salaries of one professional staff person who is projected to work an estimated annual average of 1732 hours at $25 per hour ($43,300), and one clerical staff person who will work an estimated annual average of 344 hours at $10 per hour for a cost of $3,440.

Program Year	Estimated Number Of Responses	Type Of Staff	Estimated Number Of Burden Hours Per Response	Estimated Number Of Burden Hours
2007-2008	54	Professional	140	7560
		Clerical	30	1620
2010-2011	56	Professional	25	1269
		Clerical	5	270
		Average Total	30	2052
2011-2012	56	Professional	47	2538
		Clerical	10	540
		Average Total	57	2052
2012-2013	56	Professional	25	1269
		Clerical	5	270
		Average Total	30	2052
Averaged prior 2 years’ burden for each year (beginning 2013-14)	56	Professional Clerical Total	36 7 43	2016 392 2408
Decrease for TP	56	Professional Clerical Total	31 5 36	1736 280 2016
Increase for reporting on progress toward levels	56*	Professional Clerical Total	35 5 40	1960 280 2240
2013-2014	56*	Professional Clerical Total	35 5 40	1960 280 2240
2014-2015	56*	Professional Clerical Total	35 5 40	1960 280 2240
2015-2016	56*	Professional Clerical Total	35 5 40	1960 280 2240
Annual Average	56*	n/a	40	2240

(Blue denotes the adjustments made to the estimated burden to address the 1) Average of two years of burden due to eliminating alternating years of negotiation, 2) Decrease for Tech Prep, and the 3) Increase for periodic reporting for States that miss the 90% mark for three or more consecutive years.)

The revised “Estimated Number of Responses” from 54 to 56 (as seen in column 2) reflect the addition of two United States territories, the Republic of Palau and American Samoa. These territories are now required to submit a Perkins IV State plan and/or revisions to the OVAE. In past years these territories submitted their state plans and budgets to the Office of Elementary and Secondary Education.

13. Estimate of cost to respondent.

The total capital and start-up costs for this collection are zero. The information collection will not require

the purchase of any capital equipment or 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 are not included in this estimate.

The total for 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 not already identified in question 12 of this supporting statement.

14. Estimate of costs to the Federal Government.

The Federal cost is estimated to be approximately $24,551. This includes salaries of program staff who will review State plans and State plan revisions. The method used to estimate the cost is as follows:

Program Office Staff:

3 GS-12 X 40 hours = $4,238

5 GS-13 X 40 hours = $8,400

6 GS-14 X 40 hours = $11,913

TOTAL = $24,551

TOTAL ESTIMATED FEDERAL COST = $ 24,551

15. Reasons for program changes or adjustments.

There is a program change increase of +188 total annual burden; this collection period (2013-2016) will distribute the burden equally from year to year – prior collections were calculated on an alternating year of negotiation for performance levels for 2 years. From this point on, in each year, States will negotiate performance levels for the upcoming year of collection, rather than doing so in alternating years.

16. Plans for tabulation and publication.

There are no plans for complex analytical techniques or for publication of data from this collection, although each state plan is a public document.

17. Display of OMB expiration date.

We are not seeking this approval.

18. Exceptions to the certification statement.

This request is in compliance with 5 CFR 1320.9.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection of information does not employ statistical methods.

5