Supporting Statement A EO14000_3_12_21_FINAL

Tracking and OMB Number: xxxx-NEW

Revised: 03/xx/2021

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

1. Explain the circumstances that make the collection of information necessary. What is the purpose for this information collection? Identify any legal or administrative requirements that necessitate the collection. Include a citation that authorizes the collection of information. 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, list the sections with a brief description of the information collection requirement, and/or changes to sections, if applicable.

The U.S. Department of Education (Department) intends to collect lessons learned and best practices fom the field to populate the Safer Schools and Campuses Best Practices Clearinghouse (Clearinghouse) in response to the directive to do so in Executive Order 14000 issued on January 21, 2021, by the President.

The purpose for this new collection is to ensure that the Department has sufficient information to review and, if appropriate, approve submissions to include in the Clearinghouse.

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 will use this information to review each submission, in partnership with other Federal agencies as necessary, in order to make a determination on approving each submission and including it in the Clearinghouse.

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. Please identify systems or websites used to electronically collect this information. Also describe any consideration given to using technology to reduce burden. If there is an increase or decrease in burden related to using technology (e.g. using an electronic form, system or website from paper), please explain in number 12.

If they choose to participate, teachers, faculty, staff, schools, districts, early childhood education providers, institutions of higher education (IHEs), other places of educational instruction, and States must submit lessons learned and best practices via email to [email protected]. The basis for this decision was to provide the least amount of burden on those entities that wish to share their experiences to support all members of the education community.

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.

This is a unique collection. There are no other standardized means for teachers, faculty, staff, schools, districts, early childhood education providers, IHEs, other places of educational instruction, or States to submit this information.

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.

To minimize the burden on small businesses or other small entities, the Department requests minimal supporting information along with submissions. This minimal information will allow the Department to correctly categorize submissions to support end-users.

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.

Supporting the reopening and continued operation of schools, districts, early childhood education providers, IHE’s, and other places of educational instruction is critical at this time. COVID-19 has caused unprecedented disruption to all aspects of daily life, chief among them the disruption to schooling at all grade levels. Lack of face-to-face instruction has negatively impacted students, families, and communities. Not only do students face learning loss, but students and teachers face challenges to their physical and emotional well-being as a result of the disruption to schooling. In order for this country to recover from the pandemic, students needs to be able to return to face-to-face learning and schools need to be better equipped for future crises. Sharing lessons learned and best practices is a critical way to help support a safe return to face-to-face instrucstion and help ensure that schools remain open.

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 that apply to this collection.

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.

Include a citation for the 60 day comment period (e.g. Vol. 84 FR ##### and the date of publication). Summarize public comments received in response to the 60 day notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. If only non-substantive comments are provided, please provide a statement to that effect and that it did not relate or warrant any changes to this information collection request. In your comments, please also indicate the number of public comments received.

For the 30 day notice, indicate that a notice will be published.

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 is requesting emergency clearance and OMB approval in order to collect lessons learned and best practices from the field as soon as possible. Members of the education community often turn to each other for information, resources, and support. The Clearinghouse will serve as an important vehicle for information sharing across teachers, faculty, staff, schools, districts, early childhood education providers, IHEs, other places of educational instruction, and States on a large-scale basis. This vehicle will allow for more than sharing among schools in a district or districts in a State. The Clearinghouse will allow users to find lessons learned and best practices specific to their needs and contexts.

The Department will publish 60- and 30-day Federal Register notices as required by 5 CFR 1320.8(d), soliciting comments on the information collection at that time.

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

No payments or gifts are involved in this information collection.

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.¹ 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 confidentiality of the data. If no PII will be collected, state that no assurance of confidentiality is provided to respondents. If the Paperwork Burden Statement is not included physically on a form, you may include it here. Please ensure that your response per respondent matches the estimate provided in number 12.

There is no assurance of confidentiality provided to respondents with regard to required information. We do not request any Personally Identifiable Information.

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.

This collection does not ask questions of a sensitive nature.

8. Provide estimates of the hour burden for this current information collection request. The statement should:

• Provide an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. Address changes in burden due to the use of technology (if applicable). Generally, estimates should not include burden hours for customary and usual business practices.

• Please do not include increases in burden and respondents numerically in this table. Explain these changes in number 15.

• 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. 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 this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burden in the table below.

• Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. Use this site to research the appropriate wage rate. 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. If there is no cost to respondents, indicate by entering 0 in the chart below and/or provide a statement.

Provide a descriptive narrative here in addition to completing the table below with burden hour estimates.

The burden estimate is based on the time teachers, faculty, staff, schools, districts, early childhood education providers, IHEs, other places of educational instruction, and State staff will take to prepare and submit lessons learned and best practices. The average respondent burden for preparing and submitted materials is estimated at 1.5 hours. This includes reading the instructions, collecting the information needed, providing the information requested for inclusion with a submission, and emailing it to the [email protected] mailbox. The estimated salary for staff that will prepare and submit to the mailbox is $30 per hour. The total burden is estimated as follows:

300 Respondents x 1.5 hours per respondent = 450 hours per year

Total Respondent Hours for 2021 = 450 hours

x $30 per hour

Total Respondent Cost for 2021 = $13,500

The number of respondents is an estimate based on previous experience with another similar clearinghouse. The number of respondents may change as we conduct the actual collection.

Estimated One-Time Burden and Respondent Costs Table

Information Activity or IC (with type of respondent)	Number of Respondents	Number of Responses	Average Burden Hours per Response	Total Annual Burden Hours	Estimated Respondent Average Hourly Wage	Total Annual Costs (hourly wage x total burden hours)
Clearinghouse Submissions	300	1	1.5	450	$30	$13,500
Annualized Totals	300	1	1.5	450	$30	$13,500

Please ensure the annual total burden, respondents and response match those entered in IC Data Parts 1 and 2, and the response per respondent matches the Paperwork Burden Statement that must be included on all forms.

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 :

Such costs, if incurred, would be incidental.

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.

Tasks for review:

• Review the submitted teacher, faculty, staff, school, district, early childhood education provider, IHE, other places of educational instruction, and State lessons learned and best practices:

  • Teams of Department staff (e.g., early childhood, PreK-12, and higher education teams, respectively) and, as necessary, staff from other Federal agencies such as the Department of Health and Human Services or the Centers for Disease Control and Prevention will independently review each submission and recommend inclusion in the Clearinghouse.

  • Teams will meet together subsequent to independent review to determine final approval of each submission to include in the Clearinghouse.

  • Meetings will be documented and all submission determinations tracked.

  • If a submission is determined not eligible for inclusion in the Clearinghouse, a two-three sentence reason will be provided.

• 300 lesson learned/best practice submissions @ 1 per .50 hours = 150 hours

• 5 staff @ $45/hour = $225/hour

• Total = $33,750

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).

Provide a descriptive narrative for the reasons of any change in addition to completing the table with the burden hour change(s) here.

This is a new information collection to collect lessons learned and best practices related to the safe reopening and continued operation of early childhood education providers, PreK12 schools, and IHE’s. Submissions are completely voluntary.

	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate
Total Burden		450 hours
Total Responses		300
Total Costs (if applicable)		$13,500

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.

The Department will post on the Clearinghouse the results of this information collection. The Department will begin collecting lessons learned and best practices in March of 2021 and stop in September 2021.

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.

The expiration date for OMB approval of the information collection will be displayed.

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

We do not propose any exceptions to the certification statements identified in the Certification of Paperwork Reduction Act.

1 Requests for this information are in accordance with the Privacy Act of 1974 and the following ED and OMB policies and guidance: 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; ED OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information).

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