PN Extension Grant SS _4.13_v3

OMB Number: 1855-NEW

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB Number: 1855-NEW

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 section. Please limit pasted text to no longer than 3 pages. 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.

This is a request for emergency clearance of the funding announcement of the Promise Neighborhoods (PN) Extension Grant. The funding announcement is the instrument through which the Department will comply with the Consolidated Appropriations Act 2018 (the Appropriations Act) Public Law 115-141. The Appropriations Act directs the Department to make extension awards to fiscal year (FY) 2011 and FY 2012 Promise Neighborhoods (PN) implementation grantees. The Appropriations Act states that “…no later than June 1, 2018 (emphasis added), the Secretary shall award extension grants under such section on a competitive basis to implementation grantees that have demonstrated the ability to collect, track, and report longitudinal data on performance indicators established by the Department and required to be reported on annually as part of the initial implementation grant; demonstrated the most positive and promising results during their initial implementation grant based on such indicators, emphasizing getting children ready to learn; demonstrated a commitment to operating in the most underserved and under-resourced, including rural, areas; and propose continuing to pursue ambitious goals during an extension of that grant.” In order to comply with the Appropriations Act the Office of Innovation and Improvement will need to design a program specific instrument to conduct a competition for the PN extension funds.

Pursuant to 5 CFR 1320.13, the Department requests that OMB review this information collection under its emergency procedures. This request for emergency clearance is based on missing a statutory deadline. The Appropriations Act requires that awards be made no later than June 1, 2018. The Appropriations Act became public law on March 23, 2018. There are 70 calendar days from March 23, 2018 to May 31, 2018. The June 1^st date does not allow for a 30-day public comment period and 30-day OMB review period. We are also requesting no public comment period.

PN grantees provide a range of programs, services, and supports (collectively referred to as PN solutions) designed to improve educational and developmental outcomes of students from cradle-to-career continuum in our most distressed communities. PN implementation grants have provided schools with tutors, staff training, curriculum, materials, preschool and early learning opportunities, after and summer programming, and college and career programs. PN implementation grants also provided solutions targeted to student’s families and the communities in which they live – responding to issues such as limited and low quality early childhood learning, increasing crime, limited access to healthy food (i.e. food deserts), inadequate housing, and high unemployment. Combined the FY 2012 and FY 2011 PN implementation grantees serve communities (where on average 40 percent of the population live below the federal poverty line) with nearly 80,000 children under18 year of age and 85 schools enrolling over 41,000 students.

Several of the eligible applicants have shared with the Department and members of Congress the dire need for these funds to be awarded as soon as possible. These grantees explained that funds awarded under the initial PN implementation grant have been expended and they will need to close-out all grant operations in mid to late June without additional funds. While the potential award in September may provide additional funding, services provided to the pre-school and kindergarten through grade 12 students will be needed before the school year starts. An award in September would be especially disruptive for those grantees with year round school schedules, where school resumes for its students mid-July. One grantee, which is a subset of the twelve, reported that if extension funds are awarded after June 1^st in addition to laying off 67 staff (employed by the grantee and its partners) the following supports and services will not be available at the after June:

• 74 slots for preschool;

• college preparatory supports to over 1,110 middle and high schools students;

• leadership development programming that provide 33 residents with professional development to support their community in creating better, healthier neighborhoods;

• supports such as tutoring, reading programs, and enrichment opportunities to over 6,000 elementary, middle and high students; and

• services of outreach specialists, Promotoras, who respond to families in need of assistance with food/nutrition, emergency shelter, counseling services, parenting classes, employment assistance. Promotoras have provided supports to nearly 600 students and their families.

Grantees also shared issues related to “re-starting” if funds are not received timely. The administrative burden to the grantee of “re-starting” the grant is further amplified in these distressed, low-resourced, and high poverty communities where issues like obtaining space and high qualified staff will not be easily resolved. Of particular concern is staff. Grantees explained that staff have developed strong, solid relationships with students, their families and the community. To receive funds after June will mean staff layoffs and it is not likely that these staff will be available to resume positions in September. A noted administrative burden is the recruiting, hiring, and training of new staff. Time to find equally qualified new staff will further delaying resuming disruptive services, supports, and programs.

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 funding announcement will be provided to five FY 2011 and seven FY 2012 PN implementation grantees to compete for an extension of funds and time to their initial PN grant. The funding announcement will be emailed to the 12 PN implementation grantees and posted on the Office of Innovation and Improvement website.

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 information collection involves the use of the Department’s G5 system which supports electronic submission of responses. All 12 eligible entities used the Department’s G5 system to submit applications for the initial PN implementation grant and thus prior experience exists, resulting in reduced burden. Also, the Appropriations Act states that applicants demonstrate, “…the ability to collect, track, and report longitudinal data on performance indicators established by the Department and required to be reported on annually as part of the initial implementation grant.” All 12 eligible entities have reported these data in the PN reporting system and can readily and easily retrieve this information from that reporting system.

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 Question 2 above.

The parameters for the competition established in the Appropriations Act is substantially different from those used for the initial PN implementation grant competition. The information collection instrument used for the initial PN implementation grant competition focused on the applicant’s proposed project (prospective in nature) while the parameters for the PN Extension competition are based on the applicant’s past performance (retrospective in nature).

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less than 50,000.

The PN information collection does not impact 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.

Through the PN implementation grant communities created a continuum of cradle-through-college-to-career solutions (i.e., services, programs, and other supports) of both educational programs and family and community supports, with great schools at the center. Communities used the PN implementation grant to integrate programs and break down agency “silos” so that solutions are implemented effectively and efficiently across the agencies. These communities have made gains in providing opportunities for all children and youth to have access to great schools and strong systems of family and community supports to attain an excellent education and successfully transition to college and a career. The timely award of extension funds will provide a subset of FY 2011 and FY 2012 PN implementation grants to sustain and scale up proven, effective solutions. The gains made during the PN implementation project may be at risk if solutions are severed as the time needed to re-establish partnerships, re-gain public trust, re-hire grant staff, and resume grant programming may prove to be detrimental.

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.

Respondents will be required to prepare a written response to the collection of information in fewer than 30 days after receipt of the instrument.

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.

The Department published an emergency notice in the Federal Register and will follow this timeline:

To allow for the Department to come within 10 business days of the statutory deadline of June 1, 2018 we are requesting an emergency clearance by April 26, 2018. If a funding announcement can be released on April 26, 2018 awards could be announced on June 15, 2018 and allows for:

• 28 calendar days for applicants to prepare and submit a response (April 26-May 23, 2018);

• 1 business day for ED to screen applications and assign to peer reviewers (May 24, 2018);

• 7 calendar days for peer reviewers to read, score, and participate in panel calls (May 25-31, 2018 – During this period staff will also review all budgets to ensure costs are allowable, allocable, and reasonable. Also, May 28^th is a federal holiday);

• 2 business days for PN staff to develop a proposed funding slate (June 1-4, 2018);

• 4 business days for Department review and approval of proposed funding slate (June 5-8, 2018);

• 1 business day for ED to commit awards (June 11, 2018);

• 3 business days for Congressional notification (June 12-14, 2018); and

• 1 business day for ED to obligate awards and notify successful applicants (June 15, 2018).

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

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

10. 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 ICRAS’ Part 2 IC form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 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). 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.

There are no assurances of confidentiality; the Department makes no pledge about the confidentially of the data. All submissions in response to the information collection will be posted on the Department’s website.

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.

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 Question 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. (The table should at minimum include Respondent types, Number of Respondents and Responses, Hours/Response, and Total Hours)

• 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 Question 14.

The Department estimates of the hour burden of the collection of information to be 472 hours. Respondents to the information collection are nine (9) not-for-profits organizations (NFPO) and three (3) institutions of higher education (IHE)¹ with the burden hour for all entities of 39 hours and 20 minutes for a single response to the information collection. The number of hours for respondents to respond to selection criteria is estimated to be half the time needed to complete the initial PN implementation application. Time to complete all other forms was taken for each form’s burden statement. The estimate of annualized cost to respondents is based on hourly rate of GS13, step 5 @$52.66/hour. The total per respondent is $2,064 and $24,856 for all 12 respondents.

Instrument/Form	Respondent Type	Number of Respondents and Responses	Annual Hours/ Response	Total Hours
Response to selection criteria included in announcement	NFPO, IHE	12 respondents, 1 response/respondent	30 hours	360
PN Abstract	NFPO, IHE	12 respondents, 1 response/respondent	45 minutes	9
Appendix A	NFPO, IHE	12 respondents, 1 response/respondent	180 minutes	36
ED Supplemental to the SF424	NFPO, IHE	12 respondents, 1 response/respondent	30 minutes	6
Standard Assurances for Non-Construction Programs (SF424B)	NFPO, IHE	12 respondents, 1 response/respondent	15 minutes	3
ED 524 Budget Form	NFPO, IHE	12 respondents, 1 response/respondent	60 minutes	12
Budget Narrative	NFPO, IHE	12 respondents, 1 response/respondent	180 minutes	36
Grants.gov Lobbying Form	NFPO, IHE	12 respondents, 1 response/respondent	10 minutes	2
Lobbying Disclosure Form (SF LLL) and Instructions	NFPO, IHE	12 respondents, 1 response/respondent	10 minutes	2
General Education Provisions Act (GEPA) Requirements – Section 427	NFPO, IHE	12 respondents, 1 response/respondent	30 minutes	6
Total estimated burden hours				472

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 Questions 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. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Question 12.

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M):

Total Annualized Costs Requested:

There are no annualized capital/startup costs for this collection.

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 Questions 12, 13, and 14 in a single table.

Estimated annualized cost to the Federal government is $15,720.

Item	Method of Cost Estimate	Total Cost
Program Staff Develop information collection (1 FTE @ 20 hours) Prepare and conduct informational webinar for respondents (1 FTE@ 5 hours) Recruit peer reviewers (1 FTE @ 2 hours) Develop peer reviewer training and supporting materials (1 FTE @ 5 hours) Screen submissions (2 FTEs @ 1 hour) Respond to questions (1 FTE @ 5 hours) Serve as panel moderators (4 FTEs @ 20 hours) Review budgets (2 FTEs @ 4 hours) Prepare slate (1 FTE @ 2 hours) Redact and post submissions (2 FTEs @ 5 hours) TOTAL FTE Hours = 139	Number of hours x hourly rate of GS13, step 5. 139 FTE Hours @ 52.66	$7,320
Reimbursement of Peer Reviewers	14 peer reviewers, each reading 3 applications @ $200/application	$8,400
Total		$15,720

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 (if applicable).

This is a new collection; there is a program change increase of 472 annual 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.

The Department will post on its website redacted, 508 compliant versions of each information collection submission within 30 days of awards being announced.

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 best estimate for a schedule for the PN extension competition is:

• April 26, 2018 – Funding Opportunity Notice forwarded to eligible applicants

• April 26 – May 23, 2018 – Application Period

• May 24, 2018 – Application Screening

• May 25 – 31, 2018 – Peer Review

• May 25, 2018 – Budget Review

• June 1 – 4 , 2018 – Slate Development

• June 5 – 11, 2018 – Department Clearance of Slate

• June 12 – Commit Awards

• June 12 – 14, 2018 – Congressional Notification

• June 15 – Obligate Awards and Notify Successful Applicants

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 Department will display the expiration date for OMB approval of the information collection.

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

There are exceptions to the certification statement identified in the Certification of Paperwork Reduction Act.

1 While Indian Tribe or Tribal organization (as defined in section 4 of the Indian Self-Determination and Education Assistance Act – 25 U.S.C. 5304) were eligible to apply for FY 2011 and FY 2012 implementation grants, no awards were made to an Indian Tribe or Tribal organization so these entities are not represented in the eligible applicant pool.

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