18100021 2016_Supporting_Statement

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Indian Education Formula Grant Program Application

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The purpose of Indian Education Formula Grant to Local Agencies, as authorized under Title VI, Part A, Subpart 1 of the Every Student Succeeds Act (ESSA) (Sections 6111-6119 of the Elementary and Secondary Education Act (ESEA), as amended; 20 U.S.C. §§6421-6429) is to assist applicants to meet the unique educational and culturally-related academic needs of American Indian and Alaska Native students so that the students can meet the challenging State academic standards. The Indian Education Formula Grant (CFDA 84.060A) requires the annual submission of the application from the local education agency (LEA), tribe, Indian organization (IO) or Indian community based organization (ICBO). The amount of the grant award for each applicant is determined by a formula based on the reported number of American Indian/Alaska Native students identified in the application, the state per pupil expenditure, and the total appropriation available. Applicants provide the data required for applying for funding electronically, and the Office of Indian Education (OIE) is able to apply electronic tools to facilitate their review and analysis leading to grant awards. The system has been named Formula Grant Electronic Application System for Indian Education (Formula Grant EASIE) and it is located in the EDFacts System (ESS) website. Applicants submit data through Formula Grant EASIE in two parts, Part I and Part II, which occur in different timeframes. Part I relates to collecting student counts and Part II relates primarily to performance and budget information.

To be eligible for funding, the applicant must submit both Part I and Part II of the application by the published deadlines. The information collection is necessary to meet the Government Performance and Results Act (GPRA) requirements.

On December 10, 2015, the President signed into law the ESSA, which amended the ESEA. As a result, several technical corrections need to be made to Formula Grant EASIE. In Part I, two new eligible applicants were added; in Part II one question was added, and objectives and assurances were updated. Modifications have also been made to the supporting documentation (sample evidence of eligibility agreement for tribes and Indian organizations, parent committee form, sample evidence of eligibility document for ICBO) previously approved under clearance number 1810-0021. The revisions to the Formula Grant EASIE system result in a minor reduction in the number of burden hours, based upon adjustments to the estimates regarding how much time respondents will devote to completing these forms.

OMB Reporting History and Legislative Authority

Clearance was granted for the EASIE Part I and EASIE Part II in a revised information collection by OIE under OMB No. 1810-0021 through July 31, 2019.

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.

The Department of Education uses the information to determine applicant eligibility, allocation, and whether the proposed project meets the purpose of the legislation. Applicants complete the application in two parts, with two established deadlines. The information collected from each part ensures all required documents are provided. Projects are funded annually for one budget year. The information is also used for reporting under GPRA and OESE Leading Indicators.

3. 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 for adopting this means of collection. Also describe any consideration of information technology to reduce burden.

Since December 2006, this information has been collected through an electronic system, as a component of EDFacts, the Department’s data system for elementary and secondary education. The system is web-based and includes the entire applicant submission process. A paper submission form is available to those applicants that request a waiver of the electronic system due to a lack of Internet access. However, in the nine years of implementation of EASIE, no applicant has requested paper submission.

The use of technology affords ED staff greater access to and use of data by (1) providing staff with completed applications more quickly; (2) aggregating and analyzing responses to specific questions more quickly; and (3) storing and managing the 1,300 applications and supporting documents received each year from applicants electronically.

Electronic collection affords greater efficiency for grantees by (1) eliminating the need to print and mail the application; (2) providing technical assistance from ED staff and a Partner Support Center who can view their responses online; (3) ensuring that all questions are completed fully and correctly. Additionally, the web-based system pre-populates information collected during registration, so ED does not request duplicate information from applicants. The application also calculates tables and charts to reduce burden on the applicants.

4. Describe 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.

No duplication of effort exists. This information collection requests information specifically for Indian education programs authorized under section 6121-6122 of the Every Student Succeeds Act. Applicants are required to provide information that addresses the statutory purpose and program requirements. Although there are other Indian education programs in the Department, they are authorized under different legislation and their purposes and requirements differ from those under this program.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-1), describe any methods used to minimize burden.

All information is submitted electronically streamlining the collection, so this method benefits small entities minimizing their burden.

6. Describe the 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.

The information provided by the applicants addresses all required documentation established by legislative requirements as authorized by Title VI, Part A, Subpart 1 of the ESSA, in addition to 34 CFR 75.720, and 2 CFR part 200.301. Formula Grant EASIE (Part I, Part II and APR) reduces entity burden and increases accuracy for both applicants and Department staff by entering standardized and comprehensive information into a specific online database. The information collected determines applicant eligibility, allocation, and whether the proposed project meets the purpose of the legislation. From each part, the data collected ensures all required documents are provided and application is certified by an authorized representative. It is necessary to evaluate the applications for completeness and to identify funding levels for each of the applications for grants to be awarded by July 1.

If this information is not collected, the Department will be unable to make grant awards in a timely manner. Data is generated quickly and uniformly to reduce burden on the applicants, to increase the quality of data that can be used for evaluation, to make policy decisions, and to inform Congress.

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;

Only one application per fiscal year is awarded. Respondents submit the information collection annually for each new grant year.

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

The time period from the date of availability of the information collection, as published in the Federal Register, to the date by which respondents must respond (i.e., the closing date which is also published in the Federal Register) will be at least 30 days for Part I or Part II.

• requiring respondents to submit more than an original and two copies of any document;

Respondents are required to submit applications electronically through the web-based EASIE system unless they have no Internet connection or inadequate Web access. Applicants that meet the exception to submitting an application via EASIE are not required 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;

Respondents will not be required to retain 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 the study;

The information collection is not connected with a statistical survey.

• requiring the use of statistical data classification that has not been reviewed and approved by OMB;

The information collection is not connected with a statistical survey or statistical data classification.

• 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

The information collection does not request data that is confidential.

• requiring respondents to submit proprietary trade secrets, or other confidential information the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

The information collection does not request data that is of a proprietary nature or confidential.

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 any public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

• 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 3 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.

OIE published the appropriate Federal Register Notices to solicit public comment on this collection; and there were no public comments received during the 60-day public comment period.

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

No payments or gifts to respondents will be provided.

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

We provide no assurance of confidentiality, and do not request confidential information. However, some applicants may include information within an application that is personally identifiable, such as contact information for staff. Any personally identifiable information is not released under the exemptions of the Freedom of Information Act.

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.

Information of a sensitive nature is not requested.

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.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

• Provide estimates of annualized costs 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. Instead the cost should be included in Item 14.

Burden Hours

On an annual basis, approximately 1,300 applications are submitted. Applicants submit once per year which includes both Part I and Part II. When an applicant must submit a full application for both EASIE Part I and Part II, we estimate that this will take 6 hours per applicant. However, applicants can maintain project objectives for up to four years. In a year in which an applicant maintains its project objectives, we estimate that the submission of the application will take 3 hours per applicant.

In the first year, each applicant will have to complete a full application; in subsequent years, we estimate that approximately half of the applicants will complete a full application, and half of the applicants will maintain their project objectives. Therefore, we estimate the burden for applicants across the three year period as follows:

Year 1: 1300 applications x 6 hours = 7,800 burden hours

Year 2: 650 applications x 6 hours + 650 applications x 3 hours = 5,850 burden hours

Year 3: 650 applications x 6 hours + 650 applications x 3 hours = 5,850 burden hours

Across the three year period for which we seek information collection approval, this results in an estimated annual burden for applicants of 6500 burden hours.

During any given grant cycle, approximately 10,000 new ED 506 forms are filled out annually and maintained by LEAs. Since ED 506 forms only need to be filled out once during a child’s K-12 career these forms reflect the entry of new students into any Indian formula grant program. We estimate that each new form takes .309 hours to complete, so 10,000 new forms annually results in a total 3,090 burden hours.

Therefore, in total, we estimate the annual burden hours at 9,590, including 3090 burden hours for the submission of new ED 506 forms and 6500 burden hours for the submission of applications.

Respondent Costs

For preparing the application, we estimate the respondent costs using the hourly rates of a GS 5/1 and GS 12/1 in Washington, D.C.

The cost to respondents for compilation of the information and completion of the application is based on the estimated average per year for each type of respondent. For each application, we estimate that 75 percent of the burden hours will be completed at a pay rate of $16.90/hour (including review of instructions, data compilation, and data entry), and that 25 percent of the burden hours will be completed at a pay rate of $37.13/hour (review and certification of final application).

Accordingly, when preparing the application, we estimate that 1625 total hours will cost $37.13/hour, for a cost of $60,336.25, and 4875 hours will cost $16.90/hour, for a cost of $82,387.50. In total, the estimated 9,590 hours will cost $165,126.25.

Additionally, we use the Federal minimum wage to calculate the estimated costs of completing the ED 506 form. We estimate that 10,000 forms will be completed annually, and that it will take .309 hours to complete each form. At $7.25 per hour, this results in a cost of $22,402.50.

With these two elements combined, this information collection will result in total respondent costs of $165,126.25.

Summary

	Respondents	Hours/ response	Total Annual Hours	Total Cost
EASIE Part I Student Count and Part II Project and Budget Information	1,300	6 (Year 1); 3 or 6 (Years 2/ 3)	6,500	$142,723.75
EASIE Part I Student Form (ED 506)	10,000	0.309	3,090	$22,402.50
TOTAL BURDEN			9,590	$165,126.25

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

There is no additional annual cost burden to respondents and recordkeepers from this collection of information.

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. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

The EASIE software that collects the applications for the Title VI Indian Education Formula Grants is operated and supported under a contract that is a task order under the master EDFacts contract. The estimated annual cost of support for the EASIE software is $350,000. This includes operations and maintenance and a partner support center that assists applicants in the process of submitting.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

There is an adjustment increase of 487 annual burden hours. The adjustments in burden result from changes to the estimations regarding the amount of time affected parties will devote to submitting the relevant information, and adjustments to the estimated wages of individuals responsible for completing the forms.

16. For collections of information whose results will be published, outline plans for tabulation and publication.

Results of the individual information collected will not be published.

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.

Such approval is not being requested.

18. Explain each exception to the certification statement identified in Item 20, “Certification of Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the certifications.

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