REAP 2015 1810-0646 Supporting Statement for Paperwork Reduction Act Submissions

REAP 2015 1810-0646 Supporting Statement for Paperwork Reduction Act Submissions.docx

Application for the Rural Education Achievement Program (REAP)

OMB: 1810-0646

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Rural Education Achievement Program (REAP)

Information Collection to Support Grant Funding Process


  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.


Part B of Title VI of the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act (P.L. 107-110), authorizes the Secretary of Education to award funds under two grant programs that are designed to address the unique needs of rural school districts – the Small, Rural School Achievement (SRSA) Program (ESEA Section 6212) and the Rural and Low-Income School (RLIS) Program (ESEA Section 6221).


The Department awards funds for both grant programs based on a determination of the eligibility of individual school districts, and calculating formula allocations for each eligible district. An extension of this data collection package is needed to provide the information necessary for the Department to make the grant awards.


Form 1 consists of a spreadsheet through which State educational agencies (SEAs) provide the Department eligibility and allocation data for both the RLIS and SRSA programs. Form 1 is supplemented with:

  1. a document that SEAs use to submit corrections to the REAP spreadsheet;

  2. a form for SEAs to report the Local education agencies (LEAs) in their States that meet the statutory alternative rural definition; and

  3. a form through which SEAs can obtain or verify the NCES locale code assignment of individual schools within a district.


Form 2 consists of the application package for LEAs under the REAP SRSA program (CFDA #84.358A).


Under the SRSA program, the Secretary awards grants directly to LEAs on a formula basis. Eligibility for this program is based on rural status and average daily attendance (ADA) for the district by December 1st of each year. To be eligible, an LEA must: 1) (a) have a total ADA of less than 600 students, or (b) serve only schools located in counties with a total population density of fewer than 10 persons per square mile; and 2) (a) serve only schools that have an NCES school locale code of 7 or 8, or (b) be located in an area of the State defined as rural by a governmental agency of that State. Allocations are based on the ADA numbers for eligible LEAs and the LEA’s previous year’s allocations under the following ESEA provisions: 1) subpart 2 of Title II (Teacher and Principal Training and Recruiting); 2) section 2412(a)(2)(A) of Title II (Technology Grants); 3) section 4114 (Safe and Drug Free Schools); and 4) Part A of Title V (Innovative Programs).


The Department only collects information that is essential to making the awards in the SRSA application form. As a result, the SRSA application form is only one page. The Department only requires eligible LEAs to apply once, during their initial funding year; the applications are retained and used for each succeeding fiscal year for which the LEA remains eligible for a grant under the SRSA program.


  1. 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 information collected from SEAs through Form 1, the REAP eligibility spreadsheet, which collects eligibility and allocation data, is used by the program office in coordination with Budget Service to determine school district eligibility for the program and to allocate funds to eligible districts.


The information from Form 2 (the SRSA application package) is used to process grant awards under the SRSA program.


  1. 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 of using information technology to reduce burden.


(Form 1) Beginning with the FY 2013 grant year, the program office piloted the use of an online web portal, MAX.gov – through which SEAs could submit, save, and track their eligibility spreadsheets. MAX.gov was implemented in order to further streamline the data submission process, provide version control, and put an end to the back-and forth spreadsheet e-mails between the REAP program office and SEAs. The success of this innovation in meeting its stated goals is reflected in the SEA participation levels: after two years, SEA participation in and use of MAX.gov has increased exponentially, from an initial “pilot cadre” of seven SEAs in FY 2013, to all 49 REAP-eligible SEAs in FY 2015.


(Form 2) SRSA- eligible LEAs submit their applications through the Department’s G5 electronic submission system.


  1. Efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use of the purposes described in Item 2 above.


Form 1 collects LEA-level data from States that is required to determine LEA eligibility to participate in both REAP formula grant programs program and to determine LEA level budget allocations. The system that we have instituted for determining eligibility is time-bound and incorporates data from several sources. The process that we use is similar to the processes the Department uses to determine eligibility and allocations for Title I and other formula grant programs, none of which relies solely on EDFacts as the data source for making those determinations. After numerous discussions with EDFacts staff, we have determined jointly that it is not feasible at this juncture for EDFacts data to be the primary source of data support the REAP eligibility determination process. As an example of the REAP Program’s need to rely on data outside of EDFacts, the LEA-level average daily attendance (ADA) that we collect from SEAs on the REAP eligibility spreadsheets is defined in Section 6231 of the REAP statute as: “a census to determine the number of students in average daily attendance in kindergarten through grade 12 at the schools served by the agency.” This definition is not consistent with the definition of ADA that States use to provide ADA for the EDFacts collection.


We continue to explore with EDFacts ways that EDFacts data might support our needs and further reduce the burden on SEAs. For the past six years, the REAP program office has collaborated with EDFacts staff to align, to the extent possible, REAP data definitions and elements with EDFacts data collection protocols. Our objective is to shift a number of data elements from the REAP spreadsheet to the EDFacts annual data collection, and thereby reduce the annual reporting burden that REAP imposes on States. In general, the data that SRSA requires and the timelines within which those data are needed to make eligibility determinations and allocation decisions remain incompatible with the EDFacts data element definitions and timelines for data collection.


In addition, we use data from the EDFacts/CCD collection to help develop our universe of schools, along with the NCES Locale Code assignments derived from Census data analysis. We then match the locale code data to individual schools within each district to determine each district’s eligibility. The poverty data used for RLIS eligibility also comes from the Census.


Form 2 requests a subset of the information requested in Standard Form 424 (Application for Federal Financial Assistance), which consists of the minimum needed to make grant awards. The only information that is common to Form 424 and Form 1 (Eligibility Spreadsheet) of this collection is the NCES LEA ID number, which will be used to link allocation and application data to make awards.


  1. Information impacts small businesses or other small entities (Item 8b of IC Data Part 2), describe any methods used to minimize burden.


Small LEAs are affected by this program. In order to minimize burden for these small entities, the Department uses an application package that contains only a minimal request for data- a subset of the information requested in Standard Form 424 and information required by the statute. The Department also intends to make these applications available as electronic applications, which will also minimize burden.


Small businesses are not affected by this collection.


  1. 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.


If the information requested is not collected, the Department will be unable to make grant awards, because the formula allocations cannot be calculated without data from SEAs and LEAs.


  1. Special circumstances that would cause an information collection to be conducted in a manner inconsistent with 5 CFR 1320. 5.


This collection is consistent with the paperwork burden regulations of 5 CFR 1320.5.


  1. 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.


The Department consulted with nine SEAs and asked them to estimate the burden for these collections at the district level. The burden estimates in this document are based on those responses. The Department has not received comments from SEAs or LEAs on the issue of data collection and burden during the past two years that the collection package has been in use. The Department published a 60-and 30-day FRN soliciting public comments and received none during the 60-day comment period.


  1. Payment or gifts to respondents, other than remuneration of contractors or grantees.


No payment or gifts will be provided.


  1. Assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulations, or agency policy.


There is no assurance of confidentiality. All data collected is in the public domain.


  1. Justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.


This collection does not ask questions of a sensitive nature.


  1. Estimates of the hour burden of the collection of information and the annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories.


The total annual reporting and recordkeeping burden for the collection is estimated to be 3,277 hours.


For Form 1, the maximum number of respondents is 49 SEAs. The average burden per respondent is 36 hours and number of responses per applicant is one per annum. The total estimated burden to SEAs is estimated to be 1,764 hours per annum. In addition, LEAs will review and verify the data entered by the State at an estimated burden of 15 minutes per LEA for 5,000 LEAs. The total LEA burden is approximately 1,250 hours. The total estimated burden hours for Form 1 for SEAs and LEAs combined is 3,112 hours.


For Form 2, the maximum number of respondents is 500. The average burden per response is 20 minutes and total number of responses per applicant is one. The data collection occurs annually. The total burden is approximately 165 hours.

Estimate of the total annual cost burden to respondents or record keepers for capital expenses resulting from the collection of information.


The total annual cost burden to respondents is estimated at $59,230.


For Form 1, primary costs to respondents fall into the following categories: collection of data, filling in information in the spreadsheet, review of data, and e-mailing the form. Based on an estimate of the 49 forms prepared and submitted annually, costs to respondents are estimated to be the following:


Collecting data

49 forms X 36 hours /form X $25/hour = $ 44,100

Filling in information

49 forms X 1.5 hours /form X $10/hour = $735

Data Collection/Review

5,000 LEAs X .25 hours/review X $10/hour = $12,500

E- mailing report

49 forms X .5 hours /form X $10/hour = $ 245

Total cost to respondents $57,580


For Form 2, the primary cost to respondents is for filling out the electronic application form. Based on an estimate of 500 applications prepared and submitted annually, costs to respondents are estimated to be the following:


500 applications X .33 hours /application X $10/hour = $1,650


  1. Estimate of the total annual cost burden to respondents or record keepers for capital expenses resulting from the collection of information.


This information collection does not require the use of any capital equipment, start-up costs or record keeping not included in the response to question # 12.


  1. 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.


For Form 1, program costs entail reviewing completed spreadsheets for completeness; downloading data submitted electronically; calculating allocations; and notifying States of allocations for the State and districts.


Downloading data submitted electronically

.5 hours/form X 49 forms X $40/hour = $980

Reviewing completed spreadsheets for completeness:

1.5 hours/form X 49 forms X $40/hour = $2,940

Calculating allocations

.5 hours/form X 49 forms X $40/hour = $ 980

Notifying States of allocations for the State and districts.

.5 hours/form X 49 forms X $40/hour = $ 980

.5 hours/form X 49 forms X $12/hour = $ 294

Total cost to the Federal government $ 6,174


For Form 2, program costs entail screening applications for eligibility; downloading allocation data into G5; making grant awards; and mailing award notifications.


Screening applications for eligibility 20 hours X $40/hour = $ 800

Downloading allocation data into G5 8 hours X $40/hour = $ 320

Making grant awards 250 hours X $40/hour = $10,000

Mailing award notifications 150 hours X $12/hour = $ 1,800

Total cost to the Federal government $12,920


Total combined cost to the Federal government $19,094


  1. Reasons for any program changes or adjustments.


There is an adjustment decrease of -100 annual burden hours.

For the 2012 collection, we reduced the maximum number of SEA respondents for Form 1 from 52 to 49; the District of Columbia, Hawaii, and Puerto Rico are unitary districts, and by virtue of their demographics do not meet the eligibility criteria for either RLIS or SRSA. In addition, this collection will no longer ask SEAs to provide REAP-Flex or AYP data.


For the 2012 collection, the Office of General Counsel determined that SRSA LEAs need not apply every year, so the Department has reduced the previous estimate of 4,500 applicants to an estimated 500 applicants for Form 2.


  1. Plans for tabulation and publication.


The Department will publish the list of grantees under each program and their allocations. Allocations are based on the formulas required by the statute. No complex analytical techniques will be used.


  1. Reasons not display the expiration date for OMB approval.


The information collection will display the expiration date for OMB approval.


  1. Exception to the certification statement identified in the “Certification for Paperwork Reduction Act Submissions.”


There are no exceptions to the certification statement.


  1. Collections of Information Employing Statistical Methods


This information collection will not employ statistical methods.

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File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSupporting Statement for Paperwork Reduction Act Submissions
AuthorI.R.G.
File Modified0000-00-00
File Created2021-01-25

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