Student Support Services Program
Request for Approval under the Paperwork Reduction Act
Supporting Statement for the New Annual Performance Report Form
Justification
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attached is a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
The Department of Education (Department) is requesting approval for a new collection. The Student Support Services Program (SSS) Annual Performance Report (APR) will expire on December 31, 2013 (OMB No.: 1840-New) for the SSS Program. The SSS 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 college students or college students with disabilities. These support services are intended to increase students’ retention and graduation rates, facilitate their transfer from two-year to four-year institutions, and foster an institutional climate supportive of the success of low-income individuals; first-generation college students; or an 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 final SSS regulations (34 CFR 646.22) amend the PE criteria the Secretary uses to award PE points. Under the final regulations, we award PE points for each criterion by determining whether the grantee met or exceeded applicable project objectives. This determination will be based on the information the grantee submits in its APR.
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 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 APR form collects aggregate and quantifiable data needed to respond to the requirements of the Government Performance and Results Act (GPRA). In the Department’s Fiscal Year 2010 Annual Performance Plan, the overall objective for the SSS Program is to: “Increase the percentage of low-income, first-generation college students who successfully pursue postsecondary education opportunities.”
The regulatory amendments (34 CFR 646.32) to recordkeeping requirements require that a SSS grantee document the services a student, who is served by more than one TRIO or other federally funded programs, is receiving from another program during the project year. This is a new data collection that also will increase a grantee's burden by an estimated two hours.
Additionally, the regulatory amendments 34 CFR 646.33 provide that grantees that choose to provide grant aid and that are required to provide matching funds because they are not eligible for the waiver (estimated at 50 percent of SSS grantees), must report the amount of matching non-federal funds that are provided to the project. This will increase the reporting burden by an estimated two hours per grantee. In total, there will be a new burden inventory of 9,234 hours for 1,034 SSS grantees
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.)
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 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. SSS Program projects have been submitting the APR via the Internet since the 2000-2001 project year, and all projects are currently required to submit the APR data via the Internet.
The data collected are summarized 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 is required to assess to determine grantees’ prior experience points and program outcomes, as described in item 2, above.
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.
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, Student Service Office 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.
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 or student;
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 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.
The Federal Register Notice, Volume 76, No. 55 dated Tuesday, March 22, 2011 pages 15955 to 15956 is attached along with the responses to the public comments.
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 5 year – even if the collection or information activity is the same as in prior periods. There may be circumstances that my preclude consultation in a specific situation. These circumstances should be explained.
Department staff interacts with grantees and members of the constituent organization for these forums at 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, SSS Program grantees frequently send Department staff suggestions and recommendations regarding the APR form. Grantees are also encouraged to comment during the announced public comment periods. The Department will publish a 60 day notice for public comment in the Federal Register.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
The Department will not provide payment or gifts to respondents.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The Department’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 SSS 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 (SSN) 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.
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 APR form does not include questions about sexual behavior and attitudes, religious beliefs, or other items that are commonly considered sensitive and private.
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 from 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 15,510 hours. We estimate approximately 1034 respondents x 1 (one) APR each @ 15 hours per respondent. APR will be submitted once a year (annually).
Estimated number of respondents 1034
Estimated preparation time 15 hours
Total estimated burden hours 15,510
(Estimated Burden: 15,510 hrs. Total number of hours [preparation time] multiplied 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 grantees to respond to this data collection is estimated as follows:
Estimated annual costs to respondents:
(1034 personnel X 12 hours @ $30 per hour) $372,240
(1034 clerical X 3 hours @ $16 per hour) $ 49,632
_________
Total estimated cost to respondents $421,872
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 costs 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 exiting 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 record for the government or (4) as part of customary and usual business or private practices.
There are no other costs to the respondents.
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 annual costs to the Federal Government:
The largest portion of the Government’s cost is borne directly by the Department 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 |
|
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) |
$150,000.00 |
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 |
Total Annual Government Cost |
$311,167.50 |
Explain the reasons for any program changes or adjustments.
A difference of 9,828 burden hours is shown because of the increased number of respondents from previous collections and the regulatory amendments to the PE criteria. Specifically, grantees must track the academic progress of SSS participants through degree completion and this will increase the reporting burden by six hours for each grantee. The final regulatory amendments to recordkeeping requirements will require that SSS grantees document the services a student, who is served by more than one TRIO or other federally funded program, is receiving from another program during the project year. This new data collection will increase a grantee's burden by an estimated two hours. For those grantees that are required to provide matching funds for grant aid (estimated at 50 percent of SSS grantees), the final regulations will increase burden by an estimated two hours per grantee for this data collection. In addition, the current burden hour estimate is based on the actual number of SSS current grantees that will respond---1,034 respondents-- rather than 947 respondents, as the result of the most recent competition for SSS program funds. The total estimated annual burden hours requested is 15,510 hours.
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.
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 SSS Program regulations
| File Type | application/msword |
| File Title | Application for Grants under the Student Support Services Program, HEA Title IV-A |
| Author | I.R.G. |
| Last Modified By | Authorised User |
| File Modified | 2011-06-17 |
| File Created | 2011-06-17 |