1820-0583 OSERS 2018 Peer Reviewer Data Form Support Statement

SUPPORTING STATEMENT (B)

FOR PAPERWORK REDUCTION ACT SUBMISSION

OSERS 2018 Peer Review Data Form

     

1. Justification

The OSERS Peer Reviewer Data Form (OPRDF) is used by OSERS staff to identify potential reviewers who would be qualified to review specific types of grant applications for funding; to provide background contact information for each potential reviewer; and to provide information on any reasonable accommodations that might be required by the individual. The previous version of the OPRDF, 1820-0583, expired on September 30, 2017 and was discontinued. This submission requests a reinstatement with changes to the previous form. The revised submission also captures a reduction in the number of respondents and burden hours due to the transition of National Institute on Disability and Rehabilitation Research from OSERS to the U.S. Department of Health and Human Services in 2015.

The revised version of the OSERS Peer Data Form included in this information collection request contains additional questions to better match field experts with the review of OSERS funding opportunities. There are also additional questions aimed to better meet the needs of peer reviewers who require reasonable accommodations.

There are legal requirements that necessitate this collection. For reviewers used to evaluate applications submitted under Part D of the Individuals with Disabilities Education Improvement Act (IDEA, H.R. 1350), the law indicates that "peer review panels" shall include, "to the extent practicable, parents of children with disabilities, individuals with disabilities, and persons from diverse backgrounds" (Section 682 (a)(1)(A) and (C)(2)(A)(ii)). Since all field experts captured in the peer review system are shared by program staff, all potential reviewers are asked to complete the data form.

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 information is used by OSERS staff to:

• Identify potential reviewers who would be appropriate to review specific types of grant applications for funding;

• Provide background information on each potential reviewer; and

• Provide information on any reasonable accommodations that might be required by the individual.

2. 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 given to using technology to reduce burden.

The peer reviewers currently receive the form from logistics contractors in a packet of competition materials emailed to them prior to serving on a peer review panel or electronically in association with a biannual update request.

2. 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.

OSERS is making a concerted effort to restrict duplicate requests for the information on this form at various stages of the review process by encouraging the logistics contractors to use the information from the completed form to pre-populate the requested information on subsequent forms requiring reviewer’s signatures or feedback.

2. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less than 50,000.

This collection of information does not involve small business or entities.

2. 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.

If this information is not collected, there will not be a systematic process for recruiting well-qualified reviewers, identifying them for specific panel reviews and updating their contact information. At any time, approximately 30% of the reviewer files contain data that are out-of-date, such as old addresses, employers and phone numbers. Without a mechanism to populate the PRS database with reviewer’s data, individual staff members would be asked to provide suggestions. This is both ineffective and inefficient.

Our experience is that essential contact information needs to be updated at least every two years to capture reviewers that were not used in recent competitions. Our existing database is to be updated biennially. As soon as this data collection is approved, the plan is to begin the process of asking respondents to update their data.

2. 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 than 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 that 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 circumstances which would cause information collection to be conducted in any of the manners stipulated.

2. As applicable, state that the Department has published the 60 and 30 Federal Register notices as 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 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 instruction and record keeping, 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.

This collection will be conducted in a manner consistent with the guidelines in 5 CFR 1320.8(d). A 60-day and 30-day Federal Register Notice was published seeking public comments; there were no public comments collected during the 60-day comment period.

2. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.

We pay each reviewer an honorarium commiserate with the level of effort required to review and score applications.

2. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information). If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data.

There are no assurances of confidentiality.

2. 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. The 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.

There are no questions of a sensitive nature.

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

• Indicate the number of respondents by affected public type (federal government, individuals or households, private sector – businesses or other for-profit, private sector – not-for-profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. 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 in the ROCIS IC Burden Analysis Table. (The table should at minimum include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)

• Provide estimates of annualized cost to respondents of 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, this cost should be included in Item 14.

The burden to the respondents annually would be approximately 250 hours. This estimate is based on each 1500 of respondents annually spending 15 minutes to complete the form.

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

• 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. 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 acquiring and maintaining 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 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. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12.

None

2. 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.

None

2. Explain the reasons for any program changes or adjustments. Generally, adjustments in burden result from re-estimating burden and/or from economic phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours, responses and costs (if applicable).

The revised version of the OSERS Peer Data Form included in this information collection request contains additional questions to better match field experts with the review of OSERS funding opportunities. There are also additional questions aimed to better meet the needs of peer reviewers who require reasonable accommodations. The revised submission also captures a reduction in the number of respondents and burden hours and costs due to the transition of National Institute on Disability and Rehabilitation Research to the U.S. Department of Health and Human Services in 2015 and the end of OSERS discretionary grant logistics contract. This is a reinstatement with change; the burden to the respondents annually would be approximately 250 hours. This estimate is based on each 1500 of respondents annually spending 15 minutes to complete the form. This represents a decrease in 300 responses and 200 burden hours. There are no costs associated with this collection.

	Requested	Change Due to Adjustment in Agency Estimate	Previously Approved
Annual Number of Responses for this IC	1,500	300	1,800
Annual IC Burden Hours	250	200	450
Annual IC Cost Burden (Dollars)	0	-$1,500.00	$1,500.00

2. 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 results of this data collection will not be published.

2. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The expiration date for OMB approval of the data collection will be displayed on the approved form.

2. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

There are no exceptions noted in the certification statement.

2