Supporting Statement A_msp Apr 2.11.19

Tracking and OMB Number: (XXXX) 1810-0669

Revised: 12/13/2018

RIN Number: XXXX-XXXX (if applicable)

Tracking and OMB Number: (XXXX) XXXX-XXXX

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information, or you may provide a valid URL link or paste the applicable section¹. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change). If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.

Implemented under the No Child Left Behind Act of 2001, Title II, Part B, the Mathematics and Science Partnerships (MSP) program is a formula grant program strategically designed to improve the content knowledge of teachers and the academic performance of students in mathematics and science. By funding collaborative partnerships between science, technology, engineering, and mathematics (STEM) departments at institutions of higher education (IHEs), and high-need school districts, the MSP program enables the delivery of intensive, content-rich professional development intended to improve classroom instruction and, ultimately, to raise student achievement in math and science.

Because MSP is a formula grant program, the size of individual state awards is based on student population and poverty rates, with no state receiving less than one half of one percent of the total appropriation. Each state is then responsible for administering a competitive grant making process to determine the distribution of funds across proposed MSP projects.

The program office is seeking to reinstate this collection to allow it to continue to collect Annual Performance Reports from those grantees that will need to seek a no cost extension.

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.

MSP program data are collected to measure the program’s impact on improving math and science teachers’ content knowledge and improving the academic performance of students, as well as to describe the MSP projects across the country. Reporting is structured to require MSP projects to provide standardized data, allowing the program office to examine outcomes at the project, state, and national levels.

Once approved, the 2015 APR online data collection tool provides funded projects with the opportunity to describe the structure and scope of each partnership, document impact on teachers and students, and share professional development models. Information collected is sent directly to the project’s State Coordinator for review before final submission.

Additionally, the APR provides a streamlined process to collect and aggregate program information, allowing for more effective analysis of the range of program activities across all MSP projects. The APR collects both quantitative and narrative data which are used to report regularly on the implementation and impacts of the MSP program.

As stated in Question 1, the program office is seeking to renew this collection to allow it to continue to collect Annual Performance Reports from those grantees that will need to seek a no cost extension. MSP program staff utilize both the quantitative and narrative data provided in the APR to report on the implementation and impacts of the MSP program. Aggregated APR data are analyzed to provide descriptive statistics (e.g., frequencies and means) on the characteristics of MSP projects and participants, providing a complete picture of the MSP program at the national level. Selected dimensions include the number of teachers served and students taught by those teachers, the amount of funding of the MSP program, methods of professional development delivery, and teacher and student achievement results.

Where possible, trend data is also provided, comparing data from the current performance period to data from previous periods. Narrative data further enhance our understanding of the MSP projects.

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 of adopting this means of collection. Also describe any consideration given to using technology to reduce burden.

The MSP program employs information technology to maximize the efficiency and completeness of the information gathered for this evaluation and to minimize the burden the data collection places on the MSP projects.

MSP projects complete their reporting requirements through the online APR data collection system. The online system enables project staff and State MSP coordinators to track the data submissions as the MSPs fill in the forms.

Additionally, the online APR forms are prepopulated with relevant information from previous APRs, in order to reduce time burden on respondents. When the users log onto the system, they will be allowed to update this information but will not need to provide it as part of their submission.

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.

The OMB-approved APR online data collection system was customized for the MSPs and is the only federal data collection effort of the MSPs.

5. 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 impact small businesses. Under EDGAR regulations, requirements for small entities are minimized.

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.

Each eligible partnership receiving a grant or subgrant through the MSP Program is required to report annually to the Secretary regarding the eligible partnership's progress in meeting the objectives described in the accountability plan of the partnership (Title II, Part B, section 2202 (f) of ESEA). If MSP projects did not report regularly through the APR system, it would effectively prevent ED from meeting this requirement. Additionally, this data collection standardizes the required reporting across all MSPs. This greatly enhances the quality and comparability of the resulting data.

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 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 special circumstances associated with this data collection. The data collection will comply with 5 CFR 1320.6, which authorizes OMB to approve information collections.

8. 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.

The Department will publish the 60 and 30 Federal Register notices required by 5 CFR 1320.8(d) to ensure that public feedback is solicited prior to submission to OMB. There was only one non-substantive but positive comment regarding this collection. No response was necessary since it was non-substantive in nature.

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

No payment or gift will be provided to respondents.

8. 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.² 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 is no assurance of confidentiality.

8. 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.

8. 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.

Annually, all funded MSPs are asked to complete the APR online data collection instrument. We estimate, based on initial and ongoing feedback from respondents, that the APR takes an average of 10 hours for the project directors and/or evaluators to complete. The estimated total average burden for completing the APR form across the approximately 450 partnerships is 4,500 hours.

The cost to respondents is estimated to be 44 dollars per hour, for a total estimated cost burden of approximately $198,000 across all respondents for each year of data collection.

Exhibit 1: Estimated Annualized Cost Burden to Respondents

Hourly Salary Estimate	Time per Response (hours)	Estimated Cost per Respondent	Approximate Number of Respondents	Estimated Annual Cost Across All Respondents
$44	10	$440	450	$198,000

8. 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

Total Annualized Capital/Startup Cost :

Total Annual Costs (O&M) :____________________

Total Annualized Costs Requested :

There are no annualized costs.

8. 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 total annualized cost to the federal government is fixed at $319,206. This figure was derived from the Option-Year-4 costs in the ABT contract to maintain the online system and collect and analyze the online data.

8. 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).

This is a reinstatement of hours since this collection officially expired. There are no increases in burden hours for the previous collection. The program office is reinstating this collection to allow it to continue to collect Annual Performance Reports from those grantees that will need to seek a no cost extension.

8. 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.

There are no plans to formally publish the results of this data collection. Rather, the data obtained through this data collection will be used by the Program Office to monitor the funded MSPs, to share the professional development work and findings across grantees, and to inform the Department’s Government Performance Results Act (GPRA) indicators.

The information collected for GPRA reporting includes the percentage of MSP teachers who significantly increase their content knowledge, as reflected in project-level pre- and post-assessments, and the percentage of students in classrooms of MSP teachers who score at the proficient level or above in State assessments of mathematics and science. Additionally, the APR collects information describing the MSP projects; the professional development participants; the professional development models, content, and processes; the evaluation plan; and lessons learned.

The MSP Annual Report, which includes aggregate information across grantees, is completed annually in late September and submitted to the Secretary. This report is also posted on the MSP public website.

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

All data collection instruments will include the OMB expiration date.

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

No exceptions are sought.

1 Please limit pasted text to no longer than 3 paragraphs.

2 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)

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