Supporting Statement 1076-0114 (App for Haskell and SIPI) 8-19-15

Supporting Statement A

Bureau of Indian Affairs

Application for Admission to Haskell Indian Nations University and

to Southwestern Indian Polytechnic Institute

OMB Control Number 1076-0114

Terms of Clearance: None

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

Justification

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

The purpose of the collection is to enroll students to Haskell Indian Nation University and Southwestern Indian Polytechnic Institute (SIPI) and to ensure recipients meet the requirements of the Blood Quantum Act, Public Law 99-228; the Snyder Act, Chapter 115, Public Law 67-85; and, the Indian Appropriations of the 48^th Congress, Chapter 180, page 91, For Support of Schools, July 4, 1884.

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. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

Admissions forms are used to enroll students at the Southwestern Indian Polytechnic Institute (SIPI) and Haskell Indian Nations University. The completed admissions forms are electronically entered into SIPI and Haskell Admissions and Records to maintain current data on students. The collected data is used in responding to the Bureau of Indian Education’s (BIE) budget information requests from the Department of the Interior, Office of Management and Budget, Congress and other entities as appropriate. A Privacy Act system of records notice related to this collection, BIA-22 Indian Student Records, was published in the Federal Register at 73 Fed. Reg. 40605 (July 15, 2008).

Haskell Indian Nation University Application

Page One

The first section requests for specific entry information which includes the applicant’s full name, social security number, pursuing degree and major, and the semester in which they are applying. The second section requests the applicant’s permanent mailing address, e-mail address, enrollment status, and housing status. The third section requests emergency contact information, address, telephone, and e-mail address. The fourth section requests the date and place of birth, gender, marital status, and current or pending criminal probation/parole and explanation. The last section on page one is designed to see if the applicant falls into categories which affect federal or state aid.

Page Two

The fifth section requests tribal affiliation information, which is necessary to ensure the eligibility of the applicant for enrollment. The sixth section requests for high school information, date of graduation or date of GED. The seventh section requests for any previous college information and dates attended. The eighth section requests for any activities the applicant would like to participate. The ninth section is a certification that the information on the application is true and correct, and must be signed and dated.

Page Three

This page contains the Paperwork Reduction Act and Privacy Act statements.

SIPI Application

Page One

The first part of the application asks for information about student enrollment, which semester they are applying for, and student status (new student, readmit student, transfer student, etc.). The second section requests for personal information such as the applicant’s full name, permanent and commuter address, telephone numbers, date and place of birth, social security number, gender, tribal enrollment status, secondary school status, and veteran status. There is a special section for transfer or readmission students, which requests they list all previous institutions attended. The last section asks general questions for the admissions committee to identify the needs and expectations of students while attending SIPI.

Page Two

The first part of the second page requests for more personal information which may impact the applicant while at school, such as marital status, tribal language, and family history regarding post-secondary education. The next section seeks information on the applicant’s parent’s education history. The third section requests for information about the applicant’s objectives and reasons for attending SIPI. The last section is the certification the applicant must sign and date, and if the applicant is under 18 years of age, there is another section for the parent/legal guardian to sign on behalf of the applicant.

Page Three and Four

These pages consist of clinical records for applicants. SIPI requires a physical examination and immunizations for public health reasons.

Page Five

This page contains the Paperwork Reduction Act and Privacy Act statements.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden and specifically how this collection meets GPEA requirements.

The applications can be retrieved from the school’s website at: (SIPI Application) http://www.sipi.edu/admiss/ and (Haskell Application) http://www.haskell.edu/admissions/forms.php.

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.

This information may be duplicated for students who have previously attended BIE secondary schools. For SIPI, applicants must submit an application for each semester they wish to attend due to possible changes to the student’s information.

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

This collection does not impact small business or other small entities.

6. Describe the consequence 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.

Without collecting this information, Haskell and SIPI would be not be able to ensure applicants meet the requirements of the Blood Quantum Act, Public Law 99-228; the Snyder Act, Chapter 115, Public Law 67-85; and, the Indian Appropriations of the 48^th Congress, Chapter 180, page 91, For Support of Schools, July 4, 1884, which could result in fewer eligible applicants attending the universities.

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 that 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 which 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.

There are no special circumstances that will apply to this collection.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, 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 in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A 60-day notice for public comments was published in the Federal Register on April 23, 2015 (80 FR 22739). There were no comments received in response to this notice.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, 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 three 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.

We reached out to the following individuals, as they work closely with incoming students, to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format, and the data elements to be recorded or reported:

• Joseph Carpio, Director Admissions/Financial Aid, Southwestern Indian Polytechnic Institute, P.O. Box 10146/9169 Coors Road, N.W., Albuquerque, NM 87120; phone: (505) 346-2324.

• Dorothy Stites, Director of Admissions, Haskell Indian Nations University, 155 Indian Avenue, Box 5031, Lawrence, KS 66046; phone: (785) 749-8456.

Mr. Carpio and Ms. Stites work closely with incoming students and reached out to several students to obtain their views on this information collection. Overall, the students felt the application is straight forward and the instructions were clear. The students concurred with the estimated time to complete the application. No students provided any further recommendations. Therefore, there are no changes to this information collection.

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

Respondents will not receive any payment, gift, or other remuneration for providing the information collection requirements.

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

The Privacy Act, BIA-22 Indian Student Records published in the Federal Register at 73 Fed. Reg. 40605 (July 15, 2008), provides protection for confidential information. The Federal Education Rights and Privacy Act (FERPA) regulations are followed to ensure confidentiality of 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. This 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.

SIPI requires a physical examination and immunizations for public health reasons. Criminal probation information is required due to dormitory requirements. Special services information is used to determine and implement any needed special services.

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

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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 for 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.

We receive approximately 4,000 applications annually (SIPI requires students to apply for each trimester, Haskell requires students to apply once a year), with each application taking an estimated 30 minutes to complete. Therefore, the total annual estimated burden is 2,000 hours or equivalent to $64,060.

Application (Annually)	Time	Burden Hours	Salary* (including 1.4 Benefits Multiplier)	Total
SIPI 3,000	.50 (30 minutes)	1,500	$32.03	$48,045
Haskell 1,000	.50 (30 minutes)	500	$32.03	$16,015
Total				$64,060

*Table 1, Wages & Salaries – All Workers, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by major occupational and industry group, March 2015.

We have used the Bureau of Labor Statistics, EMPLOYER COSTS FOR EMPLOYEE COMPENSATION—March 2015 (released June 10, 2015), USDL 15-1132, as a guide for our estimates, including the benefits multiplier. See http://www.bls.gov/news.release/pdf/ecec.pdf.

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* 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 (including filing fees paid for form processing). 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 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 purchasing or 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.

Applicants may use postage and envelopes to submit the application, which comes to a total cost of $2,360, with a cost of .59 cents per stamp and envelope (.49 cents for stamp and .10 cents for envelopes) for 4,000 applications. Haskell requires applicants to pay an application fee of $10 per application, which totals $10,000, for 1,000 applicants. SIPI does not require an application fee. The total annual non-hour cost burden to respondents is $12,360.

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.

The review for the applications take approximately 15 minutes for SIPI applications and 30 minutes for Haskell applications, totaling an estimated 3,250 hours to review 4,000 applications.

Institution	No. of applications reviewed @ 15 min. each	Clerk (GS-5/5) 1 $15.20/hr x 1.5 Benefits Multiplier2 = $22.80/hr	No. of applications reviewed @ 15 min. each	Technician (GS 7/5) $18.82/hr x 1.5 = $28.23/hr	No. of applications reviewed @ 15 min. each	Analyst (GS 11/5) $27.86/hr x 1.5 = $41.79/hr
SIPI	3000 x .25 = 750 hrs	750 x $22.80= $17,100.00	3000 x .25 = 750 hrs	750 x $28.23 = $21,172.50	3000 x .25 = 750 hrs	750 x $41.79 = $31,342.50
Total						= $69,615

Institution	No. of applications reviewed @ 30 min. each	Clerk (GS 6/7)1 $17.97/hr x 1.5 Benefits Multiplier2 = $26.91/hr	No. of applications reviewed @ 30 min. each	Analyst (GS 12/7) $35.36/hr x 1.5 = $53.04/hr
Haskell	1000 x .5 hour = 500 hours	500 x $26.91 = $13,455	1000 x .5 hour = 500 hours	500 x $53.04 = $26,520
Total				= $39,975

¹The salary associated with this grade and step is based on the General Schedule 2011.

²This salary, multiplied by 1.5 to cover benefits, was inferred from the Bureau of Labor Statistics, Employer Costs for Employee Compensation – March 2015; USDL 15-1132.

The total estimated annualized cost to the Federal government is $109,590.

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

Adjustments were made to the non-hour cost burden, increasing from $12,240 to $12,360. This change reflects the increase in cost for stamps.

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 information collection may be used to for budget and planning purposes, but individual persons will not be identifiable.

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.

We intend to display the OMB Control Number and the expiration date.

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

We are not seeking any exceptions to the certification statement.

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