Supporting Statement (9-2014)

3

Paperwork Reduction Act Submission

Supporting Statement

OMB No. 1405-0036

Grant Request Automated Submissions Program (GRASP) – DS-573, DS-574, DS-575, DS-576, DS-577

A. Justification

1. The Office of Overseas Schools of the Department of State (A/OPR/OS) is responsible for determining that adequate educational opportunities exist at Foreign Service Posts for dependents of U.S. Government personnel stationed abroad, and for assisting American-sponsored overseas schools to demonstrate U.S. educational philosophy and practice. With a professional staff of six Regional Education Officers to carry out these objectives at more than 230 Foreign Service Posts and involving some 198 overseas schools, it is essential that current comprehensive information regarding the schools be available so that A/OPR/OS can advise the Department of State and other foreign affairs agencies, parents and students, and the private sector regarding overseas schooling and judge the need for and utility of various types of assistance to overseas schools.

The legal requirements that authorize the function of A/OPR/OS and thereby authorize the collection of information are the Foreign Assistance Act of 1961 (as amended), and the Mutual Educational and Cultural Affairs Act of 1961 (as amended), and the Department of State Basic Authorities Act of 1956, as amended by the Foreign Service Act of 1980, PL 96-465.

2. Availability of adequate educational opportunities for dependents of Government personnel is essential to the task of recruiting, placing, and retaining of Foreign Service personnel at overseas posts. The information gathered enables the Office of Overseas Schools to advise the Department and other foreign affairs agencies regarding current and constantly-changing conditions, and enables A/OPR/OS to make judgments regarding assistance to schools for the improvement of educational opportunities. Without such information it would not be possible for the U.S. Government to recruit, place, and retain personnel at overseas posts.

3. Information is collected via electronic media. Currently all 198 schools submitting requests for assistance, do so via GRASP software. The software was recently placed online to make accessibility easier for respondents. Once accessed, the GRASP software is downloaded, the GRASP software installs the GRASP program. The GRASP program has the ability to “roll over” static data and only update changed data, which has resulted in a lessening of the burden on respondents.

4. No other agency gathers information from these schools. Information gathered by A/OPR/OS is used by all Federal foreign affairs agencies. The information is not available from any other source and requires updating on an annual basis.

5. Methods used to minimize burden for small entities are the same as those described in paragraph 3 above.

6. As noted above, current information is necessary for A/OPR/OS to be knowledgeable about schools and school programs. GRASP provides basic information about the school, its enrollment, staff, program, and budget, which is necessary for appraisal of each school seeking assistance to determine the extent of assistance required and whether the criteria governing assistance are met. The task could not be fulfilled if data were collected less frequently than annually.

7. No special circumstances require collection of information more than quarterly, require fewer than 30 days to provide information, require submission of more than original documents, require maintenance of special records, require conducting statistical surveys or require respondents to submit proprietary trade secrets.

8. The Department of State published a 60-day notice and request for comment in the Federal Register on June 23, 2014 (79 FR 35628). No comments were received.

9. No payment is made to respondents other than grants awarded based on data contained in submission.

10. There are no assurances of confidentiality given, other than those provided in federal statutes.

11. The form solicits information of a commercial nature and does not contain any questions of a sensitive nature.

12. Currently there are 198 respondents, the frequency of response is annual, the time burden is 1.5 hours, and the annual hour burden is 297 (198 x 1.5). The burden estimate is based on informal consultation with several respondents. The burden estimate for the DS-573 is 15 minutes, the DS-574 is 25 minutes, the DS-575 is 25 minutes and the DS-576 is 30 minutes. The estimated average hourly wage for a school business manager is $44.65, multiplied by 1.4 (loaded/weighted wage calculator), multiplied by burden (1.5 hours), multiplied by the number of respondents (198), yielding a monetized time burden of $18,565.47.

Burden figure per year
Number of respondents	198
Number of responses	198
Total annual hour burden	297
Monetized time burden	$18,565.47

13. Since mailing costs vary greatly throughout the world, a high estimated cost to ship a letter size envelope to post is roughly $3.05. The estimated cost for the respondents totals $604 ($3.05 per mailed response times 198). No special record keeping is required.

14. The estimated cost to the Federal government is $920.77. This estimate is based on the number of responses (198), times the average hourly processing time (198 x 7 min = 1386/60min =23.1 hours), and the average hourly salary of a program analyst (GS12/4 $39.86). This yields a cost of $920.77 (23.1 x $39.86). This represents a decrease from the cost reported at the previous renewal. This decrease is due to the elimination of burning the program onto a CD and mailing to our office for school distribution.

15. Program change – Items 13 and 14 of OMB Form 83-I reflect the minimal adjustments in the hour burden and cost burden on respondents. The estimated cost burden and the total hour burden has increased due to an increase in the number of schools. As a result of the ability to “roll over” static data and only update changes, there is a lessening of the burden on respondents. As a result of the addition of two schools, the total cost to respondents has increased.

16. The results of this collection are not published.

17. We are not seeking approval to not display the OMB expiration date.

18. No exceptions requested.

B. Collections of Information Employing Statistical Methods

This collection does not employ statistical methods.