EOC Supporting_Statement_Part_A[1]

Annual Performance Report for Grants under the
Educational Opportunity Centers Program
Supporting Statement for Request for Approval under the Paperwork Reduction Act
and 5 CFR 1320
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 hard 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 of a new Educational
Opportunity Centers Annual Performance Report (APR) form to collect annual
performance report data from projects funded by Educational Opportunity Centers
(EOC) program grants. This APR reflects new EOC program regulations enacted on
October26, 2010. The new regulations were necessitated by changes to the EOC
program in the Higher Education Opportunity Act (HEOA) of 2008. FY 2011-2012 is the
first year of a five year grant cycle during which EOC projects are required to adhere to
the new regulations.
The EOC program is one of the Federal TRIO Programs (TRIO) that provides Federal
financial assistance in the form of discretionary grants to: (a) institutions of higher
education; (b) public and private agencies and organizations including community-based
organizations with experience in serving disadvantaged youth;(c) secondary schools; (d)
combinations of such institutions, agencies and organizations. The specific goals of the
EOC program are to assist adults from disadvantaged backgrounds (e.g., low-income,
potential first-generation college students) complete secondary education and enroll in
programs of postsecondary education; and to publicize the availability of financial and
academic assistance and assist persons who seek to pursue postsecondary education in
applying for admission and student financial aid (20 U.S.C. 1070a–11 and 1070a–16).
The information that grantees submit in the APR allows the Department to annually
assess each grantee's progress in meeting their project's approved goals and objectives.
The APR data are compared with the projects’ approved objectives to determine the
projects’ accomplishments, to make decisions regarding whether funding should be
continued, and to award "prior experience" (PE) points. The regulations for this
program provide for awarding up to 15 points for prior experience (34 CR 644.22).
During a competition for new grant awards, the PE points are added to the average of
the field reader scores to arrive at a total score for each application. Funding
recommendations and decisions are primarily based on the rank order of applications
on the slate; therefore, assessment of PE points, based on data submitted in the APR, is
a crucial part of the overall application process.

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Further, this performance report form is the main source of data for the Department's
response to the requirements of the Government Performance and Results Act (GPRA)
for this program.
The Department collects information from EOC grantees under the authority of Title IV,
Part A, Subpart 2, Division 1, Sections 402A and 402F of the Higher Education Act of
1965, as amended, the program regulations in 34 CFR 644, 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 2008 as the Higher
Education Opportunity Act, which is the basis for the current program regulations, 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 projects' accomplishments; (b)
determine the number of PE points to be awarded to current grantees; and (c) aid in
compliance monitoring (i.e., to determine whether grantees are in compliance with the
selection requirements for project participants [34 CFR 644.3]).
In addition, the Department uses the APRs to produce program-level data for annual
reporting, budget submissions to OMB, Congressional hearings and inquiries, 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 given to using
technology to reduce burden.
The data collection method allows 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 enter the data online and submit the
entire report via the Internet. The EOC projects have been submitting the annual
performance report via the Internet since 1998.
The data collected are in the aggregate form at the program level, not data on individual
participants; thus the reports are a low-level security risk. Nonetheless, the Web site is
secured to ensure that the data are seen only by authorized individuals and are
protected from network hackers. Further, online data edits are in place to ensure the
accuracy and integrity of the data submitted.
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 grantees submit in their performance reports is unique to each
project and is not collected elsewhere, no duplication exists. No other instrument is
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available to collect the information that the program needs to assess prior experience or
program outcomes. The data collected in the APRsare fundamental to this program.
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 affect 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.
The collection of performance reports is required annually. 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 proposed in its initial
grant application. In addition, the information is needed to award PE points to grantees.
Without this data collection, the Department would not have the data to assess the PE
provision of the authorizing statute, respond to the GPRA and other program
performance and efficiency measures, or 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 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.

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This information collection is conducted in a manner consistent with 5 CFR 1320.5(d)(2).
As applicable, the Department has published the 60 day Federal Register notice as required by 5
CFR 1320.8(d), solicited comments on the information collection prior to submission to OMB.
Twenty-four respondent’s submitted approximately 66 individual comments (i.e., multiple
comments from respondents) were received after the 60-day comment period. The
Department compiled a summary and analysis of the comments as well as information on
changes to the proposed EOC APR in response to these 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 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 staff members have attended a number of state, regional, and national meetings at
which the Department solicited informal views and comments on reporting requirements from
grantees and other interested persons. A separate 30-day Federal Register notice will be
published to solicit public comment on the new APR form following the 60-day Federal Register
notice.
9. 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.
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
No assurances of confidentiality are provided to the respondents.
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 performance report form does not include questions about sexual behavior and
attitudes, religious beliefs, or other matters that are commonly considered sensitive and
private.

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

Indicate the number of respondents by affected public type (federal government,
individuals or households, private sector – businesses or other for-profit, private
sector – not-for-profit institutions, farms, state, local or tribal governments),
frequency of response, annual hour burden, and an explanation of how the burden
was estimated, including identification of burden type: recordkeeping, reporting or
third party disclosure. All narrative should be included in item 12. 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.



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.

Estimated burden hour for this collection of information is 1,024. We estimate approximately
128 respondents. The performance reports are submitted annually.

Public Sector

96

Estimated
Preparation Time,
per respondent
8 hours

Private Sector

32

8 hours

Total estimated
burden hours

128

8 hours

Number of
Respondents

Total estimated
burden hours
768 hours
256 hours
1,024 hours

(Estimated burden: 1,024 hrs. Total number of hours (preparation time) multiplied by the total
number of respondents equals estimated burden hours). Preparation time includes 6 hours for
professional staff to gather the information using computerized technology and 2 hours for
clerical staff to enter the data into the Web-based form.
Professional staff
(128 respondents X 6 hours X $35 per hour)

$26,880

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Clerical staff
(128 clerical staff members X 2 hours X $18 per hour)
Total estimated cost to all respondents

$4,608
$31,488

Note: As many of the respondents are project staff whose salaries are largely financed with
Federal grant funds, the Department believes that the actual cost to respondents is lower than
those indicated above but cannot provide an accurate estimate at this time.
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 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.

There are no other costs to the respondents associated with this information collection.
Grantees are required by program regulations to collect and maintain this information. The
costs to transmit the data electronically via the Web are customary and usual business practices.
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.

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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 collecting,
aggregating, and disseminating the information.
Designing performance report form
120 hours at $40 per hour
Overhead (est. at 50%): 120 times $20

$7,200

Clearing performance report form
120 hours at $40 per hour
Overhead (est. at 50%): 120 times $20
Annual updates to Web application, Web site hosting, help
desk, and data processing (contractor’s costs)
Analyses of data and preparation of national summary
reports and individual project data (contractor’s costs)
Professional staff to review and edit reports for
dissemination
160 hours at $40 per hour
Overhead (est. at 50%): 160 times $20
TOTAL FEDERAL COST

$7,200
$80,000
$90,000
$9,600

$194,000

15. Explain the reasons for any program changes or adjustments.
In previous years, the same APR form was used for two of the TRIO programs (Talent
Search and EOC) because of the similarities in the data collected for each program.
However, statutory changes and subsequent new regulations resulted in significant
differences in the performance measures for these two programs. Therefore, this form
will only be used to collect data on the EOC participants. Additionally, the final
regulatory amendments to recordkeeping requirements require that an EOC grantee
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 change will not result in an increase in burden 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.
Collected information will be analyzed annually to determine if each grantee is meeting
its approved goals and objectives and to award PE points. Performance measures and
efficiency measures for the two programs, based on data conveyed in grantees' APRs,
are disseminated in the Department's Annual Program Performance Plan. In addition,
the Department's Web site provides data on performance and efficiency measures,
beginning with the 2007–08 performance period, at the grantee level; this more

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detailed reporting has been made possible due to improvements in accuracy resulting
from incorporating the standard objectives into the report form.
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 OMB's approval of
the information collection.
18. Explain each exception to the certification statement identified in the Certification of
Paperwork Reduction Act.
There are no exceptions to the certification statement.
B. Collections of Information Employing Statistical Methods
This collection does not employ statistical methods.

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