Supporting Statement Part A
Date Originally Submitted:
July 18, 2007
Date Revisions Submitted:
November 5, 2007
Contract Number:
ED-06-CO-0028
Submitted to:
Gil Garcia
Institute of Education Sciences
U.S. Department of Education
Submitted by:
Ludwig D. van Broekhuizen
REL-Southeast
SERVE Center
915 Northridge Street, Second Floor
Greensboro, NC 27403-2112
(800) 755-3277
(336) 315-7400
TABLE OF CONTENTS
OMB Package Supporting Statement A
Circumstances that Make Collection of Information Necessary 1
How the Information will be Used, by Whom, and for What Purpose 2
Use of Technical Collection Techniques and Information Technology 2
Consequences if Study is not Conducted or if Conducted Less Frequently 3
Appendix List
Appendix A: Federal Register Notice
Appendix B: Needs Assessment Protocol
Appendix C: Documentation of UNCG IRB Approval
Appendix D: Letter to Conference Attendees
Supporting Statement for Request for OMB Approval of Data Collection/Needs Assessment for the REL-SE
Part A. Justification
Explain the circumstances that make data 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 U.S. Department of Education’s Institute of Education Sciences has contracted with The SERVE Center at the University of North Carolina at Greensboro to operate the Regional Educational Laboratory for the Southeast (REL-SE). A continuous, thorough needs assessment process to identify regional informational priorities of educators is a requirement of the current REL contract. The proposed program of needs sensing, or market research, is one component of a comprehensive approach to determining the needs of educators in Alabama, Florida, Georgia, Mississippi, North Carolina and South Carolina.
The Regional Educational Laboratory-Southeast (REL-SE) is one of ten such laboratories funded by the Institute of Education Sciences at the U.S. Department of Education. The information collection proposed here for OMB approval is in response to the requirement in the statement of work from the Request for Proposals for the Regional Educational Laboratories:
Assessment of regional education needs shall be conducted through continuing surveys of the education needs, strengths, and weaknesses within the region. The contractor shall conduct an assessment of regional needs using a process of open hearings, and other solicitation of the views of schools, teachers, administrators, parents, librarians, local education agencies, and State educational agencies within the region.
See Appendix A for the OMB Federal Register Notice for the Proposed Data Collection for the REL-SE Needs Assessment
As a REL focused on the goal of improving evidence-based decision making, perhaps the most critical factor in our work is the extent to which we can tap into real questions, problems, and issues where empirical evidence can provide needed guidance. Thus we need a systematic way of collecting data from clients to guide our work. Our planned program of market research is designed to assist the REL-SE in understanding the needs of education stakeholders and their demands for information to inform critical decisions.
The purposes of our program of market research are to:
Understand the high priority informational needs of educators, policymakers, and others, particularly in regard to areas such as; (a) school improvement and academic achievement; (b) professional development strategies; (c) high school reform; (d) teacher quality; (e) accountability systems and testing; (f) English language learners, students with disabilities, and subgroup performance; and (g) school programs intended to improve behavior, character, and responsibility.
Obtain input on what the REL-SE could do to improve the quality and process of evidence-based decision making.
The REL-SE has contracted with Curtis Research Associates to conduct this program of market research. Curtis Research Associates specializes in market research that combines qualitative and quantitative methods using the Perception Analyzer (PA), sometimes referred to as interactive group testing. It is a computer-supported, interactive data-collection and analysis system that incorporates quantitative and qualitative methods. A facilitator uses a protocol (Appendix B) to collect data in group settings of under 40 participants. The market research information gathering sessions proposed here are one component of a larger needs assessment process by which the REL-SE hopes to understand regional needs for information and translate these needs into products and services. The other aspects of the larger needs assessment process are based on our ongoing interactions with state departments and other educators in the region around our plan of work.
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 will be used by the staff of the REL-SE as a component of its comprehensive needs sensing efforts relative to identifying questions and issues of critical interest to educators. That is, this information will be used to plan for research, publications, and technical assistance needed in the region. Curtis Research Associates, the sub-contractor, will provide summaries of the information gathered from the individual market research sessions. In addition, information across sessions will be summarized to compare and contrast responses of different groups and to summarize responses within each state in our region.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other 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 using information technology to reduce burden.
The REL-SE contracted with Curtis Research Associates for this component of our needs sensing activities. Curtis Research Associates will use both qualitative and quantitative methods in these sessions using the Perception Analyzer (PA), sometimes referred to as interactive group testing. It is a computer-supported, interactive data-collection and analysis system that bridges the gap between quantitative and qualitative methods. A market research facilitator, using the protocol attached, meets with participants in a group session. Participants are shown how to use hand-held dials to individually answer some questions.
That is, each individual group participant has a dial to use to enter a quantitative rating or response. As each question is asked by the facilitator, the responses from the dials are electronically recorded and tallied on the computer so that the group’s responses from any one question or set of questions can be displayed by the facilitator and used to prompt further discussion. The facilitator can use the displayed frequency data to probe for the reasons for the distributions of responses obtained from the group. Thus, the qualitative aspect of the Market Research protocol enables the facilitator to explore participants’ needs more extensively.
Customized tabulation software allows banner tables to be produced and data can be exported into database formats for additional analysis or tracking over time. The PA accommodates any number of respondents. This approach will allow us to quantitatively identify the most important needs of constituent groups. The methodology also provides the opportunity to qualitatively explore how those needs might best be met by REL-SE programs.
Describe efforts to identify duplication. Show specifically why any similar information available cannot be used or modified for use for the purposes described in item 2 above.
The data collected through the market research sessions will not duplicate any other needs sensing activities in the region. There are no other organizations that we know of with the goal of supporting evidence-based decision making in the six southeastern states. For example, the Southern Regional Education Board (SREB), an education policy organization working in the Southeast, maintains databases on a number of important regional education issues, but does not collect information regarding the needs of educators for evidence-based information. In addition, the Council of Chief State School Officers maintains databases of key educational indicators but does not examine the need for state and district support for utilizing evidence base in program adoption and implementation decisions.
Finally, the REL-SE’s contract with the Institute of Education Sciences requires that we conduct market research to ensure that our products and services are based on emerging and expressed high priority informational needs of our clients.
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.
This collection of information does not impact small businesses.
Describe the consequence 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.
Given the dynamic environment of education, it is important that the REL-SE identify emerging needs of its clients for evidence-based education. This also enables the REL-SE to focus its programs and funding in the areas of greatest need in the Southeast. Less frequent data collection means that we would have less than a complete picture of emerging needs in each of our states. Each state context is somewhat unique, requiring market research sessions in each. It is also important to understand the needs at various levels of the educational system (e.g., state, district), thus, requiring sessions across various role types. We have tried to reduce burden by ensuring that we use existing meetings as settings for the market research sessions. There are no instances proposed in which the sole reason for the participants coming together is to participate in a market research session.
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 that 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 that 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 respondent 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 data collection.
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 buy the agency in response to these comments. Specifically address comments received on cost and hour burden. Consultation with representatives of those from who 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.
Below is wording to be used for documentation of the Federal Register notice:
In accordance with the Paperwork Reduction Act of 1995, the public was given 60 days to review and comment on the Federal Register Notice (Month Day, 2007, Vol. xx, No. xxx, Pgs. xxxxx - xxxxx).
REL-SE staff and our marketing consultant, Curtis Research Associates were consulted about the content of the draft instrument. The instrument has been revised several times based on feedback from REL-SE staff and Curtis Research Associates.
A copy of the Federal Register Notice is attached in Appendix A.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
The REL-SE selected a focus group marketing approach to needs sensing so that we could get quantitative data as well as qualitative data from a wide spectrum of educators in each state. We believe that through these methods we will obtain richer, more current and relevant information than through other survey methods. Consequently, we want to attract to our focus groups individuals randomly selected, representative of participants in state-sponsored meetings, and reflective of the wide range of educators. We believe that the proposed incentives will attract the invited educators to our meetings.
$50 gift cards will be given as incentives to participants who agree to participate in market research sessions that coincide with their attendance at a state-sponsored conference. The incentives will be given post- information collection. The purpose of the incentives is to have a representative sample of meeting participants engage in a discussion of their evidence-based education information needs. The state- sponsored meetings that they are attending offer a full schedule of professional development, networking and other activities. We provide incentives so that the randomly selected participants will give two hours of their meeting time to our needs-sensing sessions.
The focus group burden for participants is approximately 1.5 hours with an additional professional development component of 30 minutes. The amount of the incentive given is less than the average participant would earn working 1.5 hours, based on the average hourly rate for school principals ($35.62 an hour) and superintendents ($65.42 an hour), as referenced on page 7, Item 12, Table 1.
Participants in REL-SE sponsored activities (members of the Consortium for Evidence Based Education and members of the REL-SE Board) who participate in market research sessions embedded in these REL-SE activities will not be given incentives to participate.
The literature on providing incentives to participate in marketing sessions, including focus groups and survey research provides support for offering an incentive to individuals to participate in focus groups. In their book, Focus Groups: A practical guide for applied research (3rd Edition), Krueger and Casey state that “Focus groups are unique from other data-gathering processes in terms of the investment that must be made by the individual. Incentives are needed because it takes effort to participate in a focus group…The level of individual contribution exceeds that needed for other forms of data gathering…such as mail-out or telephone interviews.” (p. 90). Several studies have been conducted examining the effect of incentives on response rates. Yu and Cooper (1983) found that: a. The amount of incentive had a positive linear relation to response rates in personal interviews, telephone interviews, and mail surveys, and b. Persons receiving a monetary incentive responded at a higher rate than those not offered an incentive. Church (1993) found in a meta-analysis of 38 studies, that the inclusion of a monetary incentive increased response rates in mail surveys.
Most experimental research on the topic focuses on providing incentives to individuals to participate in medical research. No experimental research could be identified that examined educators’ participation rates in focus groups or marketing research and the influence on their participation by incentives.
References
Church, Allan H. (1993). Estimating the effect of incentives on mail survey response, Public Opinion Quarterly, 57(1), 62-79.
Krueger, R. A., & Casey, M. A. (2000). Focus Groups, 3rd edition: A practical guide for applied research. Thousand Oaks, CA: Sage Publications.
Yu, J., & Cooper, H. (1983). A quantitative review of research design effects on response rates to questionnaires. Journal of Marketing Research, 36-44.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Under Confidentiality Assurances for the Education Sciences Reform Act (ESRA Act of 2002), the REL-SE pledges that all individually identifiable information about students, their families, and their schools shall remain confidential. To this end ESRA 2002 requires and REL-SE pledges that no person may:
Use any individually identifiable information furnished under the provisions of this section for any purpose other than statistical purposes for which it is supplied;
Make any publication whereby the data furnished by any particular person under this section can be identified; or
Permit anyone other than the individuals authorized by the Commissioner to examine the individual reports.
The source of this language is the Restricted Use Data Procedures Manual, Chapter 1.4, Education Sciences Reform Act of 2002, Confidentiality Standards, pg. 10.
In addition, the Privacy Act (5 USC 552a) is the statutory policy on which confidentiality assurance to respondents is based and the REL-SE has submitted the plan for this marketing research to the Institutional Review Board of UNCG and has received its approval (Appendix C).
The letter of recruitment (Appendix D) states that participants’ responses will be summarized across the sample, and that no individual responses will be reported. All participants will sign consent forms (Appendix E) and be assured of the confidentiality of their responses. Participants may elect to withdraw from the facilitated group session at any time, and may also omit questions that they do not want to answer in the group setting.
Responses to this data collection will be used only for statistical purposes. The reports prepared for this study will summarize findings across the sample and will not associate responses with a specific district or individual. We will not provide information that identifies participants, their school district to anyone outside the study team, except as required by law.
No identified individual responses will be reported. Data will be summarized by market research session.
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.
This market research facilitated protocol is focused on providing the REL-SE with summary information on the perceptions of educators relative to their critical informational needs. There are no potentially sensitive items asked in this protocol. Participants will be informed that they may withdraw from participation, or choose to skip an item at any time during the session.
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 83-1. *Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriated 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 13.
The REL-SE will conduct these market research sessions within a two-hour block of time. The first 30 minutes will consist of an introduction to the REL mission and products and a discussion of the term evidence-based education. The market research protocol administration can take up to 1.5 hours depending on the extent of the qualitative discussions and the size of the group. The annual numbers of respondents below are estimated based on a projected 10 market research sessions annually. The projected annual meetings for 2008 include: one conference in each state targeting various role groups, one regional CEEBE meeting, two topical meetings, and one board meeting. (In 2009, the REL-SE also projects collecting data at 10 similar, annual meetings.)
In sum, for the two years remaining of proposed data collection (2008 through 2009), the number of sessions per year will total approximately 10 or less, rather than the originally proposed 20 per year.
Table 1
Annual Estimate of Burden Hours
Type of Respondent |
Number of Respondents |
Data Collection Instrument |
Number of Responses |
Hours per Respondent |
Total Time Burden Hours |
Estimated Cost to Each Respondent |
Estimated Total Cost |
Super-intendents/ district staff* |
60 |
Perception Analyzer |
60 |
1.5 |
90 |
$98.13
|
$8,831.70 |
Principals/ teachers* |
60 |
Perception Analyzer |
60 |
1.5 |
90 |
$53.50 |
$4,815.00
|
CEEBE participants |
90 |
Perception Analyzer |
90 |
1.5 |
135 |
$52.35
|
$7,067.25 |
SEA staff* |
24 |
Perception Analyzer |
24 |
1.5 |
36 |
$52.35
|
$1,884.60 |
Topical Meetings |
30 |
Perception Analyzer |
30 |
1.5 |
45 |
$52.35
|
$2,355.75 |
REL-SE Board meeting |
24 |
Perception Analyzer |
24 |
1.5 |
36 |
$ 98.13
|
$3,532.68 |
All Participants |
288 |
|
288 |
|
432 |
|
$28,486.98 |
*State conference attendees invited to market research sessions
Superintendent and district staff salaries are based on 2003-2004 average annual salary of $125,609 reported in http://www.naesp.org. According to NAESP, most Superintendents work approximately 240 days a year, or $523.33 a day/ or $65.42 an hour.
In 2004-2005 principals in the Southeast made an average of $68,398 a year, according to NAESP (http://www.naesp.org), or $285 a day/ or $35.62 an hour at 240 days a year.
For CEEBE participants, primarily district level staff, the same survey reports that central office supervisors make approximately $67,000 annually. Their daily salary is $279.17 (based on a 240 day year) or $34.90 an hour.
Salary estimates for SEA staff could not be located in the literature; therefore, we have estimated that their salaries are comparable to district staff, or $34.90 an hour.
REL-SE Board members serve in a variety of leading education roles, from State Superintendents of Education or their designees, and other prominent state educators. Salaries for these positions are not available, so we conservatively estimate that they earn closer to a district superintendent, or approximately $65.42 an hour.
The instrument will not be pre-tested – rather the first session will serve as the pre-test with only minor adjustments to the protocol expected.
Provide an estimate for 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 components. 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 or 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 purchasing or contracting out information collections 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 and 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.
There is no estimated cost burden to respondents beyond what is reported in Item #12. There are no capital or start-up costs unique to this collection of information. The major annual operational costs associated with the information collection are listed in Item #14.
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
The table below provides an estimate of the annualized cost to the Federal government for the REL-SE to conduct the market research sessions. The subcontract with Curtis Research Associates includes costs for participant travel and incentives. The REL-SE staff time includes overhead costs.
Table 2
REL-SE Market Research Group Session
Annualized Costs
Curtis Research Associates $ 102,520.00
Subcontract includes participant travel and incentives
REL-SE staff time $ 17,472.00
Approximately 40 days or 320 hours @ $54.60 an hour
REL-SE staff travel $ 20,000.00
Approximately 20 trips
Total $ 139,992.00
Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.
This is a first collection of information. This activity, to conduct a needs assessment, is a requirement of the REL-SE contract with IES.
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.
Curtis Research Associates will summarize individual session data and also generate cross-session summaries as requested or needed by the REL-SE for internal planning. There are no plans to publish or report the data gathered externally. The primary use of the data is for internal review by REL-SE staff in planning for products and services.
Data analysis will consist of reporting frequency data on quantitative items (participants’ agreement or disagreement with statements), rank ordering of issues by importance, and content analyses of open-ended questions. Responses will be summarized by session with individual state or role type comparisons provided to the REL-SE as needed for internal planning. The sessions will be scheduled such that the annual summary of session data can be summarized in the fall for use in the REL-SE staff’s annual planning process. The REL-SE Updated Annual Plan is due in December of each year 2007-2009.
Table 3
Projected Data Collection Schedule
Month, Year |
Project Task |
Client Group |
Location |
Summer-Fall 2006 |
Develop market research protocol |
|
|
Winter 2007 |
OMB Clearance Package submitted |
|
|
Winter 2007 |
Receive OMB Clearance |
|
|
Summer/Fall 2008 |
Begin market research sessions |
State, district, and school staff |
6 state-sponsored conferences (one per state) |
Fall 2008 |
Data collection |
CEEBE members regional meeting |
Atlanta, GA |
Fall 2008 |
Data collection |
SERVE/REL-SE Board members and Open Hearing |
TBD |
Summer/Fall 2008 |
Topical meetings |
TBD |
TBD |
Summer/Fall 2008 |
Summarize and report on data to REL-SE staff |
|
|
November/December 2008 |
REL-SE staff use in annual planning |
|
|
January-August 2009 |
Data collection |
State, district, and school staff |
6 state-sponsored conferences (one per state) |
Fall 2009 |
Data collection |
CEEBE members regional meeting |
TBD |
Fall 2009 |
Data collection |
SERVE/REL-SE Board members and Open Hearing |
TBD |
Summer/Fall 2009 |
Topical meetings |
TBD |
TBD |
Summer/Fall 2009 |
Summarize and report on data to REL-SE staff |
|
|
November/December 2009 |
REL-SE staff use in annual planning |
|
|
The breakdown of market research by state, year and client group is detailed in the table below:
Table 4
Tentative Schedule of Marketing Meetings
State |
Year |
Event |
Client Group |
Alabama |
2008 |
Alabama Mega Meeting |
School and district staff |
2009 |
School Superintendents of Alabama Meeting |
Superintendents and district staff |
|
Florida |
2008 |
FASA/FAISA/DOE Curriculum, Instruction and Assessment Conference |
District leaders, staff, principals |
2009 |
Florida Association of District School Superintendents (FADSS) Fall Conference |
District leadership |
|
Georgia |
2008 |
Summer Georgia Association of Educational Leaders (GAEL) Conference |
District leadership and state staff |
2009 |
Summer GAEL Conference |
District leadership and state staff |
|
Mississippi |
2008 |
Mississippi Association of School Superintendents (MASS) Winter Conference |
District leadership |
2009 |
Mississippi Mega Conference |
District leadership and state staff |
|
North Carolina |
2008 |
North Carolina Accountability Conference, Winter |
District leadership and state staff |
2009 |
NC Closing the Gap Conference, Spring |
State, district and school staff |
|
South Carolina |
2008 |
South Carolina Association of School Administrators, Summer Conference |
State, district and school leaders |
2009 |
SC Association for Supervision and Curriculum Development |
School, district and state curriculum and instructional leaders |
|
Regional Meetings |
2008
|
SERVE/REL-SE Board Meeting and Open Hearing |
State Superintendents and other education leaders; parents and other public stakeholders in Open Hearing |
2 Topical Meetings |
TBD |
||
Regional CEEBE Meeting |
CEEBE Participants (state-, district-, and school level members) |
||
2009 |
SERVE/REL-SE Board Meeting and Open Hearing |
State Superintendents and other education leaders; parents and other public stakeholders in Open Hearing |
|
2 Topical Meetings |
TBD |
||
Regional CEEBE Meeting |
CEEBE Participants (state-, district-, and school level members) |
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
We are not seeking approval for this.
Explain each exception to the certification statement identified in Item 19, “certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.
There are no exceptions to the certification statement.
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File Modified | 0000-00-00 |
File Created | 0000-00-00 |