Att_Supporting Statement OMB PRA

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

RISE Award Nominee Submission

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 the Recognizing Inspirational School Employees (RISE) Award is to recognize and promote the commitment and excellence exhibited by classified school employees who provide exemplary service to students in pre-kindergarten through high school and to inspire innovation and excellence among all classified school employees.

The U.S. Department of Education (Department) invites the governor of each state to nominate up to two classified school employees by November 30, 2020. The Secretary of Education will select a single classified school employee to receive the RISE Award for that school year in spring 2021. The Department will communicate the selectee’s story in order to inspire other innovative practices and excellence among classified school employees.

The Secretary of Education is responsible for administering the RISE Award, which is authorized under Public Law No. 116-13.

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.

States receive nominations from various outside entities to select up to two nominees to ED. ED collects information on nominees from governors’ offices to select one national awardee.

ED requests information from governors’ offices that have evaluated classified school personnel according to the following categories:

A) Work performance

(B) School and community involvement

(C) Leadership and commitment

(D) Local support

(E) Enhancement of classified school employees' image in the community and schools

A classified school employee is an employee of a state or any political subdivision of a state, or an employee of a nonprofit entity, who works in any grade from pre-kindergarten through high school in any of the following occupational specialties: paraprofessional, clerical and administrative services, transportation services, food and nutrition services, custodial and maintenance services, security services, health and student services, technical services, and skilled trades. The terms used have the meaning given the terms in section 8101 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 7801).

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 of using information technology to reduce burden.

The RISE Award will use a fillable form for governors’ offices to submit nominees. States may use their own mechanisms to collect information from entities that offer nominations.

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.

States will be offered a single Nomination Form to simplify their efforts as well as technical assistance to support their selection process.

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

To minimize burden, ED asks that each nomination address five streamlined areas of performance in no more than three pages of narrative. ED will encourage states to keep their state-specific nomination processes similarly straightforward and to work with any partners already collecting information regarding excellence among classified employees.

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.

If ED cannot collect information regarding the performance of classified employees that states nominate, it will have no basis for recognizing classified employees. Without the collection, the Congressionally-mandated RISE Award is unfeasible.

In order that states may nominate candidates annually, ED must collect information annually for up to two nominees per state. This is the lowest number of nominees per state that ED can permit, according to the statute. This frequency cannot be reduced, although submission is totally voluntary and some states will choose to submit fewer nominees. ED expects to continue to make awards annually.

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 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 for this collection. Respondents submit information on a voluntary basis. Respondents are not required to retain records or submit statistical or confidential information or proprietary trade secrets.

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 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.

ED will collect public input on the substance of the award. It will continue to adapt the award based on input in subsequent years.

A 60 ay notice was published on August 19, 2019 (84 FR 40398). One public comment was received. Response to the comments are provided. A 30 day comment period will be published.

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

This information collection does not involve payment or gifts of any kind.

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

Confidential information is not collected. A SORN is being developed. Only the winner’s name will be released.

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. 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.

This information collection does not include sensitive and/or private questions.

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 in item 13 of OMB Form 83-I.

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 not be included in Item 14.

Annual Burden Hours

The burden is on two sectors: 1) governors’ offices and 2) their designated eligible nominating entities. The activities they conduct are described below, the estimated burdens for each provided separately, and the total burden then presented.

The governors’ offices solicit applications, review applications, select nominees and submit documentation to ED. Governors shall consider nominations submitted by local educational agencies, school administrators, professional associations, labor organizations, educational service agencies, nonprofit entities, private schools and their representatives, parents and students, and any other groups they deem appropriate.

The burden on these nominating entities may vary depending on the process for nomination in each state. ED will encourage governors offices to keep their process streamlined.

We estimate that 40 states might participate.

We estimate that they might receive an average of 30 nominations each.

States might spend 41 hours annually conducting outreach, completing the form.

reviewing nominations, and administering the program.

The total burden and responses for this request is 4,920 hours (120 responses X 41 hours per response.

The wage of the state employee doing this work varies greatly. A wage of $30 an hour is used in this calculation as an estimate.

Total costs related to this activity is $42,000 (40 hours X 40 states X $30/hr).

The wage of the individual doing this work varies greatly. A wage of $30 an hour is used in this calculation as an estimate.

Costs for nominating entities across the country is $36,000 (1H X 30 Nominations X 40 States X $30 hour)

13. 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 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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : $ .00

Total Annualized Costs Requested : $ .00

There are no such costs to respondents.

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 total annual cost is:

Program Office Staff:

$50.49/hr X 100 hours = $ 5,049

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

This is a new request. This results in an increase in burden and responses of 4,920 hours and 120 responses respectively.

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.

We will not publish the nominations provided to ED from states. We will, however, communicate the innovative practices of honorees.

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.

The OMB control number, expiration date, and related information will be displayed on the Nomination Form. We are not seeking this approval.

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

There are no exceptions are requested for this submission.

B. Collection of Information Employing Statistical Methods

The information collected will not employ statistical methods for gathering or analysis.

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