Student Support Services Program
Request for Approval under the Paperwork Reduction Act
Supporting Statement for the Annual Performance Report Form
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 Department of Education is requesting reinstatement without change of the previously approved annual performance report which was discontinued on November 30, 2009 (OMB No.: 1840-0525) to collect data under the Student Support Services (SSS) Program. Reinstating the report would allow the Department to collect consistent performance data from current Student Support Services grantees, who were given a one-time, one-year extension due to the negotiated rulemaking process underway to implement the Higher Education Opportunity Act (HEOA) revisions to the Higher Education Act (HEA), the authorizing statute for the program. Beginning next year and pending a final rule, all new and continuing grantees will submit performance data consistent with the changes made by the HEOA and a new package will be forwarded to include new data collection fields consistent with those changes.
The Student Support Services Program provides Federal financial assistance in the form of discretionary grants to institutions of higher education for the purpose of providing academic and other support services to low-income, first-generation or disabled college students. These support services are intended to increase students’ retention and graduation rates, facilitate their transfer from two-year to four-year colleges, and foster an institutional climate supportive of the success of low-income and first generation college students and individuals with disabilities.
The information submitted in the annual performance report is used to assign prior experience points. The Student Support Services Program authorizing statute, Title IV, Part A, Subpart 2, Chapter 1, Section 402A(c)(2)(A) of the Higher Education Act of 1965, as amended, states that “in making grants under this chapter, the Secretary shall consider each applicant’s prior experience of high quality service delivery...under the particular program for which funds are sought.” The current Student Support Services Program regulations at 34 CFR 646.22 provide for the awarding of up to 15 points for prior experience. The data provided in the annual performance report are compared with the grantee’s approved project objectives to determine the grantee’s accomplishments and to award prior experience points. During a competition for new awards, the prior experience points are added to the average of the field readers’ scores to derive a total score for an application. A slate of all applicants is developed on the basis of the total scores of the applications. Funding recommendations and decisions are primarily based on the rank order of applicants on the slate. Therefore, the assessment of prior experience points is a crucial part of the overall application process.
In addition, during non-competitive years, the reports are used to verify that grantees are making substantial progress toward the achievement of approved objectives prior to issuing continuation awards.
Further, this annual performance report form collects quantifiable data needed to respond to the requirements of the Government Performance and Results Act (GPRA). In the Department of Education’s Fiscal Year 2009 Annual Performance Plan, the overall objective for the Student Support Services Program is to: “Increase the percentage of low-income, first-generation college students who successfully pursue postsecondary education opportunities.”
Information is collected under the authority of Title IV, Part A, Subpart 2, Chapter 1, Section 402D of the Higher Education Act of 1965, as amended; the program regulations in 34 CFR Part 646; and the Education Department General Administrative Regulations (EDGAR) in 34 CFR 74.51, 75.720 and 75.732. (Attached is a copy of the authorizing statute, as amended in 1998, which is the basis for the current program regulations, also attached. A copy of the authorizing statute, as amended in 2008 by the Higher Education Opportunity Act, is also attached. It is the basis for the negotiated rulemaking process currently underway, from which final regulations are still pending.)
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 of Education uses the data collected to: (a) evaluate a grantee’s accomplishments; (b) determine, in part, the number of prior experience points to be awarded a grantee; and (c) aid in compliance monitoring.
In addition, the annual performance reports are used to collect programmatic data for purposes of annual reporting; budget submissions to OMB; Congressional hearing testimonials; Congressional inquiries; performance measuring; and responding to inquiries from higher education interest groups and the general public.
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 data being requested allow the grantees to use computerized data systems to collect, retrieve, and report the requested information. A web-based software application has been developed for grantees to use to enter the data online and submit the entire report via the Internet. Student Support Services Program projects have been submitting the annual performance report via the Internet since the 2000-2001 project year, and all projects are currently required to submit the annual performance report data via the Internet.
The data collected are summary information on project participants and services and are low-level security risk. Nonetheless, the web site is secured to ensure the data are only seen by authorized individuals and are protected from network hackers.
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.
The information submitted in this report is unique to each respondent, therefore no duplication exists as far as can be determined. There is no other collection instrument available to collect the information the Department of Education is required to assess to determine grantees’ prior experience points and program outcomes, as described in item 2, above.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not involve small businesses or other small entities.
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.
Collection of information is annual. Collection of information on a less frequent basis is not feasible. These reports are used to determine if the grantee is making satisfactory progress in meeting the goals and objectives, as proposed in its initial application, prior to awarding continuation funding. In addition, the information is needed to award prior experience points to grantees. Without this data collection, the Federal TRIO Programs will be unable to make continuation awards, comply with the prior experience provision of the authorizing statute, respond to the GPRA requirements, and develop improved policies for program administration.
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.
With one exception, no information will be collected in the manner covered under any of the special circumstances outlined. The exception is that respondents are required to retain participant records for more than three years as required under 34 CFR 74.53(b). In order to assess the impact of the program services on participating students’ academic progress, grantees are required to track the academic progress of all prior-year participants as long as they remain enrolled at the grantee institution.
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.
Department of Education staff attended a number of state, regional, and national meetings to solicit informal views and comments on the reporting requirements from grantees and other interested persons. In addition, Student Support Services Program grantees frequently send staff suggestions and recommendations regarding the annual performance report form. Grantees are also encouraged to comment during the announced public comment periods. This process will be followed again prior to the submission of the new Annual Performance Report for the Student Support Services Program but was not necessary for this extension since the form has not changed. A 60 day notice was published on July 16, 2010. The Department of Education published a 30 day notice for public comment in the Federal Register.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
The Department of Education will not provide payment or gifts to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The Department of Education’s disclosure policies adhere to the provisions of the Privacy Act of 1974 (P.L. 93-579, 5 U.S.C. 552a) and Title IV of the Higher Education Act of 1965, as amended (P.L. 102-325, Sec. 402D). The Department receives and maintains personal information on participants in the Student Support Services Program. The principal purpose for collecting this information is to administer the program, including tracking and evaluating participant progress. Providing the information on the form, including a social security number is voluntary; failure to disclose a SSN will not result in the denial of any right, benefit or privilege to which the participant is entitled.
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.
The annual performance report form does not include questions about sexual behavior and attitudes, religious beliefs, or other items that are commonly considered sensitive and private.
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 burden.
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.
Estimated burden hours for this collection of information are 6 hours. We estimate approximately 947 respondents x 1 (one) annual performance report each. Annual Performance Reports will be submitted once a year (annually).
Estimated number of respondents 947
Estimated preparation time 6 hours
Total estimated burden hours 5,682
(Estimated Burden: 6 hrs. Total number of hours [preparation time] divided by the total number of respondents equals estimated burden hours).
Most of the costs of this data collection are those of the Federal Government, since the respondents are project staff paid for the most part with Federal grant funds. Nonetheless, the annual cost to the grantee to respond to this data collection is estimated as follows:
Estimated annual costs to respondents:
(947 personnel X 5.5 hours @ $30 per hour) $156,255
(947 clerical X 0.5 hours @ $16 per hour) $ 7,576
_________
Total estimated cost to respondents $163,831
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 :
Total Annual Costs (O&M) :
____________________
Total Annualized Costs Requested :
There are no other costs to the 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.
14. Estimated annual costs to the Federal Government:
The largest portion of the Government’s cost is borne directly by the Department of Education in designing the report form, securing clearance of the form, and in collecting, aggregating and disseminating the information.
14 . Estimated annual costs to the Federal Government: |
|
Professional staff to update report form and prepare clearance package(GS 14 employee) $55 per hour X 80 hours |
$4,400.00 |
Overhead costs related to facilities, Administration and other indirect costs, plus accrual of leave and fringe benefits, estimated at 50% of salary $4,400 X 50 percent |
$2,200.00 |
Clerical staff to type, route, and copy report form$16 per hour X 10 hours Overhead costs: $160 X 50 percent |
$160.00 $80.00 |
Other Department staff to review and approve the request(GS 15 employee) $65 per hour X 5 hours Overhead costs: $325 X 50 percent |
$325.00 $162.50 |
OMB review (estimated) |
|
$45 per hour X 8 hours Overhead Costs: $360 X 50 percent |
$360.00 $180.00 |
Other Administrative Costs |
|
Cost of duplicating and mailing instructions for submitting report947 copies at $1 per copy |
$947.00 |
Posting annual performance report to World Wide Web (2 hours X 1 staff @ $55 per hour) |
$110.00 |
Annual updates to web application, web-site hosting, help deskAnd data processing (contractor costs) |
$100,000.00 |
Analyses of data and preparation of national summary and individualproject reports (contractor costs) |
$150,000.00 |
Professional staff to review and edit reports for dissemination$55 per hour X 40 hours |
$2,200.00 |
Overhead Costs: $2,200 X 50 percent |
$1,100.00 |
Printing and mailing of reports |
$7,500.00 |
Total Annual Government Cost |
$269,724.50 |
15. Explain the reasons for any program changes or adjustments.
A difference of 5,682 burden hours is shown because the previous collection was discontinued. In addition, the current burden hour estimate is based on the actual number of Student Support Services current grantees that will respond -- 947 respondents -- rather than 936 respondents, as had been the basis for the previous collection. Because the collection was discontinued, the current inventory is zero. The total estimated annual burden in hours is 5,682 hours.
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. 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.
Results of the collected information will not be published.
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.
This report form and the web site will display the expiration date for the OMB approval of the information collection.
18. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions.”
There are no exceptions to the certification statement.
This collection of information does not employ statistical methods.
Attachments:
Authorizing statute with 1998 amendments (basis for current program regulations)
Authorizing statute with changes made by the 2008 Higher Education Opportunity Act (basis for the current negotiated rulemaking process, final regulations still pending)
Current Student Support Services Program regulations
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Application for Grants under the Student Support Services Program, HEA Title IV-A |
| Author | I.R.G. |
| File Modified | 0000-00-00 |
| File Created | 2021-02-02 |