Supporting Statement RTT Program Review FINAL

Race to the Top Program Review Protocols:

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification

A.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 American Recovery and Reinvestment Act of 2009 (ARRA) provided $4.3 billion for the Race to the Top Fund (referred to in the statute as the State Incentive Grant Fund), of which approximately $4 billion was used to fund comprehensive statewide reform grants under the Race to the Top program. The U.S. Department of Education (Department) awarded Race to the Top (RTT) grants in two phases. On March 29, 2010, at the conclusion of Phase 1, the Department announced RTT grants for two states. Delaware and Tennessee received their grant awards on June 14 and July 28 respectively. On August 24, 2010, at the conclusion of Phase 2, the Department announced RTT grants to an additional 9 states and the District of Columbia. All Phase 2 grants were awarded on September 24, 2010. The Department is committed to supporting grantees as they implement ambitious reform agendas through RTT. Specifically, the Implementation and Support Unit (ISU) at the Department is dedicated to differentiating its approach based on individual State needs and supporting States to work with each other and with experts from around the nation to achieve and sustain educational reforms.

In order to fulfill our programmatic oversight responsibilities, the Department has developed a monitoring (program review) protocol that is tied directly to the RTT selection criteria and absolute priorities previously established and published in the Federal Register. Grantees will be required to submit regular progress updates on the status of the performance measures included in their proposals. Grantee responses will provide the information required for the Department to inform ongoing performance management discussions in order to make the necessary and immediate adjustment to program implementation and support, as well as provide appropriate and timely updates to the public on the progress of grantee’s program implementation.

For monthly discussions, the Department will work with the States to select two relevant application criteria based on the activities outlined in the State scope of work and application. These progress updates for all application criteria will be updated biannually in preparation for the onsite program review and a stocktake meeting with ISU leadership. In preparation for the onsite program review, States will be required to submit supporting documentation to substantiate the responses provided in their progress updates. Participating local educational agencies (LEAs) will also be required to submit annual progress updates in preparation for the onsite program review.

Additionally, grantees will be responsible for submitting information regarding fiscal accountability and oversight of RTT funds semi-annually. The initial submission will occur in preparation for the on-site program review, and an update to this information will be required prior to the stocktake meeting with ISU leadership. These questions relate to the grant administration/performance and are covered by the statute and EDGAR provisions.  For example, 34 CFR 80.20 requires that a State must account for grant funds in accordance with State laws and procedures.  It also requires that a State’s fiscal control and accounting procedures, as well those of its subgrantees and contractors, must, among other things, be sufficient to permit the tracing of expenditures of funds to a level that ensures that funds have not been used in violation of applicable Federal requirements.  Similarly 34 CFR 80.40 requires that grantees are responsible for managing the day to day activities of  grants and subgrants to assure compliance with Federal requirements and that performance goals are being achieved. 

A.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 in the form of regular progress updates and an annual accountability and oversight submission by grantees. A sampling of subgrantees will be required to submit an annual progress update and accountability and oversight information with supporting documentation.

This is a new collection. States will submit a monthly progress update to the Department that includes general questions regarding their Race to the Top plan and progress updates for two of the application criteria. The information collected in monthly progress updates for all application criteria will be updated by States semi-annually in preparation for the onsite program review and a meeting with ISU leadership. In preparation for the onsite program review, States will be required to submit supporting documentation to substantiate their progress. Annually, States will be required to submit accountability and oversight information to ensure compliance with statutory and Department regulations. The Department will use this information to assess the progress of RTT grantees in implementing the activities outlined in their approved applications.

A.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 information requested under this collection will be gathered by email. The Department has sufficient capacity to deal with the email submissions but may employ other electronic means such as an electronic grants management system if this proves to be feasible. The information gathered through this process is detailed in A2.

A.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 assurances and information requested under this collection are unique to the Race to the Top program, and the Department has not collected them in the past. Even in the event of similar or comparable information for other programs in the past, the progress updates are specific to the Race to the Top program and the information is specific to the present point in time. Therefore, any comparable information and assurances that were collected in the past would not satisfy the requirements for this program. The Department has made every effort to reduce the burden on States in producing the information.

A.5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The Secretary certifies that this proposed action will not have a significant economic impact on small entities. At most, there are 11 small entities that will be impacted but the burden will be kept to a minimum for all grantees.

 

A.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.

RTT is the largest discretionary grant program ever administered by the Department, and continues to generate high public interest both for the Department. This collection is critical to ensure the Department has the required information to inform ongoing performance management discussions with grantees in order to make the necessary and immediate adjustments to program implementation and support, as well as provide appropriate and timely updates to the public on the progress of grantee’s program implementation.

A.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.

The Department is committed to supporting States as they implement ambitious reform agendas through RTT. Specifically, the ISU is differentiating its approach based on individual State needs and tailored technical assistance that supports States to work with each other and with experts from around the nation to achieve and sustain educational reforms. Thus, ongoing communication with the Department is necessary to provide appropriate and timely assistance to States as they implement their RTT plans. Additionally, regular submission of progress updates will reduce the burden on the State when preparing for the onsite program review and meetings with ISU leadership.

This collection is consistent with 5 CFR 1320.5.

A.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.

The public will have an opportunity to comment during the clearance period for both emergency and regular public comment period notices. However, the questions in the program review protocol are closely tied to the RTT selection criteria previously established and published in the Federal Register, as well as the statutory criteria and absolute priority, so it is unlikely there will be significant public comment.

A.9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts to respondents have been made.

A.10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

There is no assurance of confidentiality.

A.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.

A.12. Provide estimates of the hour burden of the collection of information.

A. Burden hours for respondents

The Department estimates that approximately 48 entities (1 grantee + 3 subgrantees (LEAs) x 12 grantees) will engage in this collection. The average annual burden for the program review is estimated to be 56 hours per grantee and 6 hours per subgrantee (18 hours for three LEAs in each State). Across the four years of the grant, this results in 296 burden hours per grantee and 3,552 hours across all 12 grantees. The annual total burden hours are estimated at 74 hours per State (grantee + subgrantees). The burden estimate was calculated based on the amount of time it would take a typical grantee or subgrantee staff member or team of staff members to complete each item.

A. State Success Factors	Hours  (Annual)
(A)(1) Articulating State’s education reform agenda and LEAs’ participation in it	3
(A)(2) Building strong statewide capacity to implement, scale and sustain proposed plans	3
(A)(3) Demonstrating significant progress in raising achievement and closing gaps	3
B. Standards and Assessments
(B)(1) Developing and adopting common standards	3
(B)(2) Developing and implementing common, high-quality assessments	3
(B)(3) Supporting the transition to enhanced standards and high-quality assessments	3
C. Data Systems to Support Instruction
(C)(1) Fully implementing a statewide longitudinal data system	3
(C)(2) Accessing and using State data	3
(C)(3) Using data to improve instruction	3
D. Great Teachers and Leaders
(D)(1) Providing alternative pathways for aspiring teachers and principals	3
(D)(2) Improving teacher and principal effectiveness based on performance	3
(D)(3) Ensuring equitable distribution of effective teachers and principals	3
(D)(4) Reporting the effectiveness of teacher and principal preparation programs	3
(D)(5) Providing effective support to teachers and principals	3
E. Turning Around the Lowest-Achieving Schools
(E)(1) Intervening in the lowest-achieving schools and LEAs	3
(E)(2) Turning around the lowest- achieving schools	3
Competitive Priority
Emphasis on Science, Technology, Engineering, and Math	3
Additional Requirements
(a) Accountability and Oversight - SEA	4
(b) Accountability and Oversight – LEA (3 LEAs for each grantee State)	6
(c) Progress Updates – LEA (3 LEAs for each grantee State)	12
(d) Logistics	1
Total hours per grantee	74

B. Cost to Respondents

The Department estimates that the per-hour cost for grantee and subgrantee employees will average $30 per person (approximately GS-12 equivalent) per hour for a total of $2,220.00 annually.

A.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: 0

Total Annual Costs (O&M): 0

_________________________________________

Total Annualized Costs Requested: 0

There are no start-up or annual costs (aside from salaries listed above) for this collection.

A.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 Federal costs will involve managing grantee submissions continuously over the life of the grant. Calculations below include the costs associated with managing the 12 grantees:

• Grade 9: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site collection) + (3 hours x 2 stocktake meetings) = 24 + 6 + 6 = 36 hours per year x 4 employees = 144 hours at 24.74 / hour = $3,563

• Grade 11: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site collection) + (3 hours x 2 stocktake meetings) = 24 + 6 + 6 = 36 hours per year x 4 employees = 144 hours at 29.93 / hour = $4,310

• Grade 12: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site collection) + (3 hours x 2 stocktake meetings) = 24 + 6 + 6 = 36 hours per year x 2 employees = 72 hours at 35.88 / hour = $2,583

• Grade 14: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site collection) + (3 hours x 2 stocktake meetings) = 24 + 6 + 6 = 36 hours per year x 1 employee =36 hours at 50.86 / hour = $1,831

• Grade 15: (2 hrs x 12 months for monthly submissions) + (6 hours for on-site collection) + (3 hours x 2 stocktake meetings) = 24 + 6 + 6 = 36 hours per year x 1 employee =36 hours at 61.76 / hour = $2,223

Total = $14,510 per year

A.15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

This is a new collection related to the Race to the Top program.

A.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.

Some of the information collected in this program review may be analyzed with performance data and shared on a government website such as recovery.gov or ed.gov.

A.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 will be displayed on the form.

A18. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

The Department is requesting an exception to the provision certifying a reduction in burden for small entities because the provision does not apply. Additionally, the provision for certifying the use of effective and efficient statistical survey methodology does not apply to this proposed action.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This information collection does not employ statistical methods.

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