2017_Supporting Statement for VUB APR-update from public comment

Tracking and OMB Number: (XXXX) XXXX-XXXX

Revised: XX/XX/XXXX

Annual Performance Report for Grants under the

Veterans Upward Bound Program

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 hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information, or you may provide a valid URL link or paste the applicable section¹. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change). If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.

The Department of Education (Department) is requesting approval of an extension of the Veterans Upward Bound (VUB) Annual Performance Report (APR) form to collect annual performance report data from projects funded by VUB program grants. There have been no changes to the form and the dates will be updated prior to publication. The VUB APR is administered in accordance with the Education Department General Administrative Regulations (EDGAR) as modified by the Uniform Guidance 2 CFR 200.

The VUB program is a type of Upward Bound Program 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; and (d) combinations of such institutions, agencies and organizations. The specific goal of VUB is to provide fundamental support and motivation to veteran participants in their preparation for college entrance and to assist them in the development of academic skills necessary for success in a program of postsecondary education. VUB provides short-term remedial or refresher courses for veterans who are high school graduates but who have delayed pursuing postsecondary education. The program also provides special services, including mathematics and science preparation, to enable veterans to make the transition to postsecondary education. Funded projects are expected to assist veterans in securing support services from other locally available resources such as the Veterans Administration, State veterans agencies, veteran associations and other State and local agencies that serve veterans. The goal of VUB is to increase the rate at which participants enroll in and graduate from institutions of postsecondary education (20 U.S.C. 1070a-13).

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 645.32). 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.

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 VUB grantees under the authority of Title IV, Part A, Subpart 2, Division 1, Sections 402A and 402B of the Higher Education Act of 1965, as amended, the program regulations in 34 CFR 643, the Education Department General Administrative Regulations (EDGAR) in 34 CFR 75.590, 75.591, 75.720, and 75.732 and CFR 200.328 of the Uniform Guidance. The authorizing statute, as amended in 2008 by the Higher Education Opportunity Act, which is the basis for the current program regulations, can be found at the following URL: http://www.2.ed.gov/programs/triovub/legislation.html.

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 prior experience 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 and to Congress, and Congressional hearings, testimonials and inquiries, and to respond 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 VUB projects have been submitting the annual performance report via the Internet since 2001.

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 available to collect the information that the program needs to assess prior experience or program outcomes. The data collected in the APR are 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 prior experience points to grantees. Without this data collection, the Department would not have the data to assess the prior experience 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.

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 34 CFR 74.53(b). In order to assess the impact of the program services on participants’ academic progress, and in anticipation of the new outcome measure for VUB which occurred as a result of the HEOA, grantees should track the academic progress of all prior-year participants until postsecondary completion.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as 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.

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 60-day Federal Register notice followed by a 30-day Federal Register notice was published to solicit public comment on the APR form.

The Department received one comment regarding the tracking of participant in postsecondary and the statement that no grantee should be denied continued funding as long as the project makes reasonable efforts to report on findings. The commenter also recommended that the Department allow projects to submit reasonable estimates when exact data are not available, so long as the estimates are based on experience and historical knowledge.

The Department assumes that, in referring to continued funding, the commenter is referencing prior experience (“PE”) points that projects may earn for accomplishing certain objectives at or above the level established in our grant competitions. These points are added to panelists’ scores from a grant competition to arrive at a total score.

Five separate objectives are involved in earning prior experience points. The two that involve prior participants measure postsecondary enrollment and postsecondary completion. Regarding the postsecondary enrollment objective, the two-year period that the Department uses (previous year and current year) was suggested by the public during the comment period for TRIO’s regulations, which may be found at https://www2.ed.gov/programs/triovub/legislation.html

The timeframe used for the postsecondary enrollment and completion objectives is known to applicants when they submit their grant applications. Applicants propose their own targets for these objectives; when they do so, they are free to take into consideration the difficulties they may encounter in tracking prior participants.

No further actions will be taken by the Department in response to this comment.

8. 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.

8. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided.² If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data.

No assurances of confidentiality are provided to the respondents. The Department makes no pledge about the confidentiality of the data.

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 performance report form does not include questions about sexual behavior and attitudes, religious beliefs, or other matters 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 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 hours for this collection of information are 833. We estimate approximately 49 respondents. The performance reports are submitted annually.

	Number of Respondents	Estimated Preparation Time, per respondent	Total estimated burden hours
Public Sector	42	17 hours	714 hours
Private Sector	7	17 hours	119 hours
Total estimated burden hours	49	17 hours	833 hours

(Estimated burden: 833 hrs. Total number of hours (preparation time) multiplied by the total number of respondents equals estimated burden hours). Preparation time includes 15 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

(49 respondents X 15 hours X $35 per hour) $25,725

Clerical staff

(49 clerical staff members X 2 hours X $18 per hour) $1,764

Total estimated cost to all respondents $27,489

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.

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.

Annual contract cost for development of APR Web application, Web-based data collection, Help Desk support, data processing, and grantee PE reports.	$44,143
Analyses of data and preparation of national statistical reports.	$46,321
Professional staff to update report form and prepare clearance package clearing performance report form: $57 per hour X 120 hours Overhead (est. at 50%): 120 times $28.50	$10,260
Professional staff to review and edit reports for dissemination: $57 per hour X 160 hours Overhead (est. at 50%): 160 times $28.50	$13,680
Clerical staff to type, route, and copy report form: $21 per hour X 15 hours                       Overhead costs (est. at 50%) 15 times $10.50	$473
Other Department staff to review and approve the request: $57 per hour X 10 hours         Overhead costs (est. at 50%) 10 times $28.50	$855
OMB review (estimated): $57 per hour X 8 hours Overhead costs (est. at 50%) 8 times $28.50	$684
TOTAL FEDERAL COST	$116,416

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in burden result from re-estimating burden and/or from economic phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours, responses and costs 9if applicable).

The number of respondents has decreased from 51 to 49 and the total burden hours have decreased from 867 to 833 over the funding cycle. The decrease in the number of projects funded is a result of the Department terminating grants due to grantees not making substantial progress. Therefore, the number of projects currently completing the APR is 49 grantees.

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 VUB, 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 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.

1 Please limit pasted text to no longer than 3 paragraphs.

2 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)

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