GAANN Supporting Statement Final

Attachment C

Supporting Statement for Paperwork Reduction Act Submissions

Graduate Assistance in Areas of National Need (GAANN)

Application for New Grants

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 Graduate Assistance in Areas of National Need (GAANN) program, authorized under 20 U.S.C. 1135, provides grants to departments and programs of higher education to support graduate fellowships for students of superior ability who demonstrate financial need. The authorizing statute for GAANN (Title VII, Part A, Subpart 2 of the Higher Education Act of 1965, as amended) requires the collection of specific data that are necessary for applicant institutions to receive an initial competitive grant and non-competing continuation grants for the second and third years. The current application (OMB #1840-0604) will expire on August 31, 2011. The Department of Education is now requesting an extension of this collection package to collect data under 34 CFR Sections 648.20, 648.31, and 648.66.

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 uses the data collected in the Application for New Grants to evaluate, score, and rank the quality of the projects proposed by the institutions of higher education applying for a grant. Data are also used to determine allowable multi-year project expenses based on statutory requirements, and to recommend funding levels for the proposed grants. If the data are not collected, the Department could not determine the quality of competing applications, which is the basis for making grant awards as required by the statute.

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.

The GAANN program participates in the Grants.gov application submission process. The GAANN application is available only through Grants.gov. Through Grants.gov, applicants are able to build and submit their proposals offline and then submit them electronically.

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.

Since the information submitted in the application is specific to the GAANN program, there is no duplication. There is no other collection instrument available to collect the information necessary to meet the purposes described in item 2 above.

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.

Institutions of higher education are the sole recipients of GAANN grants. There is no impact on small businesses or 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.

Grants awarded under this program are made annually and the data must be collected for each new competition cycle. Failure to collect this information would prohibit the Department from fulfilling its responsibility to award grants under this program.

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 included in this information collection.

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.

We published the applicable Federal Register Notices seeking public comment.

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.

Collection of this data will follow the guidelines under 5 CFR 1320.8. GAANN grantees were consulted through email, phone and the project director meeting. No changes are necessary based their comments.

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

The Department will not provide any payment or gifts to respondents.

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

There are no assurances of confidentiality provided.

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.

The application form does not include questions about sexual behavior and attitudes, religious beliefs, or other items that are commonly considered sensitive and private.

8. 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 16 of IC Data Part 1.

• 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.

The estimated total reporting burden for this data collection is 13,432 hours. This includes a total of 325 respondents (227 public universities and 98 private universities), each with an estimated response time of 41.33 hours.

	Public Universities	Private Universities
Estimated number of respondents	227	98
Estimated response time	41.33	41.33
Frequency of collection	1 annually	1 annually
Total estimated burden hours	9382	4050

The burden to each individual respondent, established at 41.33 hours, is based on feedback from respondents during previous competitions.

The estimated annual cost to a single respondent is as follows:

	Public Universities	Private Universities
Professional staff (35 hrs x $35 per hour)	$1,225	$1,225
Clerical staff (6.33 hrs x $10 per hour)	$63.30	$63.30
Total estimated cost per respondent	$1,288.30	$1,288.30
Total estimated costs to all 325 respondents (227 public universities x $1,288.30) and (98 private universities x $1,288.30)	$292,444.10	$126,253.40

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.

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M) :

Total Annualized Costs Requested :

There are no other costs to the respondent except those that would be customary and usual business practices.

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.

Estimated cost to the Federal Government:

Task	Cost	Hours	Number of Staff	Hours Total	Total Cost
Securing OMB approval once every 3 years.	$42/hr	15	4	60	$2,520
Reports Design (every 3 years)	$42/hr	20	3	60	$2,520
Sorting applications, forming review panels, assigning proposals	$42/hr	320	3	960	$40,320
Conducting Reviews	$42/hr	200	3	600	$25,200
Generate/Preparing Slates	$42/hr	40	3	120	$5,040
Slate Review and Approval	$55/hr	5	6	30	$1,650
Issuance of Awards	$42	100	2	200	$8,400
Monitoring and Technical Assistance	$42	500	2	1000	$42,000
Total Annual Cost					$127,650

8. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

There are no changes in total burden.

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 has no plans to publish any information from this collection.

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 will be displayed.

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

No exceptions are being requested.

Collection of Information Employing Statistical Methods

This collection does not employ statistical methods.