2015-16 30 day DS-2028 Supporting Statement

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

OVERSEAS SCHOOLS - GRANT STATUS REPORT
OMB Number 1405-0033

DS-2028

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.

OMB Guidelines contained in Circular A-110, require that Financial Status Reports on federal grants be submitted not less than annually. The Foreign Assistance Act of 1961, as amended (22 U.S.C. 2396(d)); Section 102 of the Mutual Educational and Cultural Affairs Act of 1961, as amended (22 U.S.C. 2452); and Section 29 of the Department of State Basic Authorities Act of 1956, as amended (22 U.S.C. 2701), authorize the function of A/OPR/OS. The policy under which A/OPR/OS conducts the Consolidated Overseas Schools Program is outlined in 2 FAM 610. GAO decision B-149441, December 6, 1962, 42 Comp. Gen. 289, states that grants to American-sponsored overseas schools are not statutory unconditional grants or gifts. It further states that it is the responsibility of the Department of State for seeing that the grant funds are applied to the purposes and objects for which they are made.

2. Consistent with new guidance from OMB, including in 2 CFR §200.327, the form DS-2028, Overseas Schools Grant Status Report, is required. Each American-sponsored overseas school submits a completed DS-2028 to embassy officials who approve the report and verify that the information submitted is consistent with post records. Information from the DS-2028 has provided A/OPR/OS professional and technical staff with the means by which obligations, expenditures and reimbursements of the grant funds are monitored to ensure the grantee is in compliance with the terms of the grant.

3. We continue to enhance our electronic form capabilities. Currently, we have placed the form DS-2028 in a Microsoft Excel spreadsheet. Form DS-2028 is sent as a link to the school along with the grant documents. School officials can complete the form electronically and forward the form to post for forwarding to A/OPR/OS. Because of security concerns with schools accessing the Department of State’s domain, they cannot access the Department’s internal forms database to complete the DS-2028.

4. No other agency gathers information from these schools. There is no duplication of the data. The Department does have access to an automated worldwide financial system (GFMS), which is used to assist in monitoring reimbursement of grant funding, but no duplicative system exists for obtaining information on obligation and expenditure of USG grant funding by the schools.

5. The information does not have a significant impact on a substantial number of small entities.

6. The DS-2028 provides the embassy and A/OPR/OS with reports, on an annual basis, of obligations, expenditures, and reimbursements under each grant. Without the data provided on the form by the respondents, the embassy and the Department would not be able to monitor the usage of USG funds as required by OMB guidelines, Comptroller General opinions, and U.S. laws.

7. No special circumstances exist with respect to this information collection.

8. A 60-day notice was published in the Federal Register on February 8, 2016 (81 FR 6571). No comments were received.

9. No payments or gifts are made to respondents, other than remuneration of grantees.

10. There is no assurance of confidentiality.

11. The form solicits information only related to usage of USG grant funds and does not contain any questions of a sensitive nature.

12. Since all information submitted on the DS-2028 by the respondents would customarily be maintained by the schools as part of their normal business practices, there is no separate burden related to collection of this information. The Department estimates the 195 respondents will spend 15 minutes annually completing the DS-2028. The annual time burden will be 48.75 (195 x 0.25), rounded up to 49 hours. The estimated average hourly wage for a school business manager is $44.65, multiplied by 0.25 (loaded/weighted wage calculator), multiplied by the number of respondents (195), giving a monetized time burden of $2,178.15.

Burden figure per year
Number of respondents	195
Number of responses	195
Total annual hour burden	48.75
Monetized time burden	$2,178.15

13. No annual costs are attributed to respondents.

14. The estimated burden to the Federal Government is $5,566.00.

The Federal Government estimate is based on the number of responses (195) and the average hourly processing times and average hourly salaries for Post and the Office of Overseas Schools.

Post:

Average hourly processing time (0.5 hr) x 195 = 97.50 (rounded to 98) hrs

Average hourly salary of an FS-04/5 Administrative Officer ($36.35) x 98 = $3,544.13

Office of Overseas Schools:

Average hourly processing time (0.25 hr) x 195 = 48.75 (rounded to 49) hrs

Average hourly salary of a GS-12/5 Program Analyst ($41.48) x 49 = $2,022.52

Total = $3544.13 + $2022.52 = $5566.65, rounded up to $ $5,567.

15. There are no program changes associated with this collection.

16. Information will not be published.

17. The Department will display the OMB expiration date.

18. No exceptions are requested.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.