Ss_1840-0595(11-5-10)

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT 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.
This request is for approval of reporting requirements that are contained in the Federal
Family Education Loan Program (FFELP) regulations (34 CFR 682.210) which address the
targeted teacher deferment provision of the Higher Education Act of 1965 as amended by
the Higher Education Amendment of 1986, sections 427(a)(2)(C)(vi), 428 (b)(1)(M)(vi), and
428 (b)(4)(A), which provide for the targeted teacher deferment.
The FFELP (34 CFR 682.210(q)), Paul Douglas Teacher Scholarship Program (34 CFR
653.50(a)), TEACH Grant Program, and Federal Perkins Loan Program (34 CFR 674.53(c))
regulations contain information collection requirements. The Chief State School Officers of
each state provide the Secretary annually with a list of proposed teacher shortage areas for
that state.
If a State does not submit the required written documentation proposing teacher shortage
areas, FFEL/SLS and Federal Perkins Loan borrowers; Douglas scholars; and TEACH
Grant recipients who teach in the state may not receive Federal program benefits to which
they may be entitled.

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 information collected is necessary for a state to support its annual request for
designation of teacher shortage areas within the state.

3. Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
forms of information technology, e.g. permitting electronic submission of responses, and
the basis for the decision of adopting this means of collection. Also describe any
consideration given to using technology to reduce burden.
State education agencies are encouraged to submit this data electronically.

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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.
A single designated agency in each state is responsible for providing the targeted teacher
shortage area proposal. There is no duplication of records that the state agencies must
maintain.

5. If the collection of information impacts small businesses or other small entities (Item
8b of IC Data Part 2), describe any methods used to minimize burden.
The information collection has no significant impact on small businesses or the 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.
Loan borrowers, Douglas scholars, and TEACH grantees will not be able to receive the loan
deferment, a reduction in teaching obligation, cancellation of their loan debt, or meet their
teaching obligation if the teacher shortage area information is not collected from the state
and designated by the Department.

7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
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requiring respondents to report information to the agency more often than
quarterly;

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requiring respondents to prepare a written response to a collection of information
in fewer than 30 days after receipt of it;

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requiring respondents to submit more than an original and two copies of any
document;

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requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records for more than three years;

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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;

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requiring the use of a statistical data classification that has not been reviewed
and approved by OMB;

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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

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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.

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.
We have consulted with the Chief State School Officers and have received their input on the
requirements associated with this collection. We have published the required 60 and 30-day
Federal Register Notices seeking public comment.

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.

10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
The information is not of a personal and confidential nature, and no assurance of
confidentially is provided. The purpose of the collection is to designate teacher shortage
areas and to distribute that information to loan administrative officials in the State Education
Agencies.

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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.
There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement
should:
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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.

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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 16 of
IC Data Part 1.

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Provide estimates of annualized cost to respondents of the hour burdens for
collections of information, identifying and using appropriate wage rate
categories. The cost of contracting out or paying outside parties for
information collection activities should not be included here. Instead, this cost
should be included in Item 14.

There are a total of 57 respondents to this annual information collection. As indicated
above, the burden estimate for this information collection is 80.0 hours per respondent.
Therefore the total annual burden is calculated as follows:
80.0 hours x 57 respondents = 4,560
The hourly estimate includes identifying and collecting the relevant information, formatting
and preparing the report response, securing appropriate signatures, and maintaining
records.

The total annual cost burden to respondents is calculated as follows:

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Professional Staff (80.0 hours@$15.00/hr)-------------Support Staff
($10.00/hr x 4.0 hours)
Estimated annual total cost for computer usage---------

$1,200.00
$40.00
$50.00
$1,290.00

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.)
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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.

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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.

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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

:

____________________

No additional costs to the states are involved.

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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 annual cost to the Federal Government for the State Teacher Shortage Area (TSA)
proposals is estimated to be $14,300.00. This cost includes staff time in (1) preparing,
printing, and mailing the solicitation for proposals; (2) reviewing the submission by the
States; (3) recording and analyzing the information and methods used to determine the TSA.
This step is necessary to ensure state compliance with the program statute and regulations;
and (4) preparation and posting of the updated nationwide listing of TSA on the Office of
Postsecondary Education web pages.
The annual costs to the Federal government are calculated as follows:
Professional Staff (300 hrs x $40.00)----------------------Support Staff (100 hrs x $12.00/hr)-----------------------Computer time, Miscellaneous (Printing of document
& mailing)
World Wide Web preparation and posting----------------(One Professional Staff x 20 hrs x $30.00/hr)
Total estimated cost to the Federal Government-----------

$12,000.00
$ 1,200.00
$
$

500.00
600.00

$14,300.00

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data
Part 1 Form.
There are no changes.

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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 are not intended for statistical use.

Letters to the Chief State School Officer designating federal teacher shortage areas are insured,
with copies distributed to several state contacts. Thereafter, a nationwide list of teacher
shortage areas is published by the Department and distributed to TSA contacts in each state,
state Douglas program officers, and CEOs of the state guarantee agencies as well as posted on
the Department of Education website.

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

18. Explain each exception to the certification statement identified in the Certification of
Paperwork Reduction Act.
There are none.

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