MSEIP 2019 Supporting Statement FINAL

OMB Number: 1840-0109 Revised: 4/17/19

RIN Number: XXXX-XXXX (if applicable)

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 Office of Postsecondary Education (OPE) is requesting a reinstatement with change of the previously approved application which will be needed for current (FY 2019) and future competitions for new awards under the Minority Science and Engineering Improvement Program (MSEIP). The previous application expired on March 31, 2018 and was discontinued.

The authorizing statute for this program, Title III, Part E, Subpart 1, Sections 350-365 of the Higher Education Act of 1965, as amended (HEA), and the governing regulations (34 CFR Part 637), require the collection of this information to determine the applicant’s eligibility.

Link to applicable legislation & regulations: http://www2.ed.gov/programs/iduesmsi/legislation.html.

There are limited changes to the application since OMB’s last review and approval of the form.

The collection of the information requested on the proposed application form is necessary to allow 2-year and 4-year, public and private, nonprofit institutions of higher education; nonprofit science-oriented organizations; and professional scientific societies to apply for grant funds under MSEIP.

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.

Applications for grants under the Minority Science and Engineering Improvement Program are submitted electronically using the Grants.gov Apply site (Grants.gov). The information collected is gathered electronically through Grants.gov for the Department of Education for the purpose of obtaining programmatic and budgetary information needed to evaluate applications and to make funding decisions based on the authorizing statute and the published selection criteria. This collection will be conducted annually, based on availability of funding for new grants under Title III, Part E, of the HEA.

Notably, without the collection of this information, the Department cannot properly screen applicants for eligibility that apply for MSEIP grants under Title III, and therefore cannot award new grants for which Congress has appropriated funds under this program.

The program staff and peer reviewers will use the information to evaluate applications and make funding decisions.

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.

OPE is committed to the reduction of paperwork. Electronic submission has reduced the burden for both the applicants and Department staff as it streamlines the application preparation, submission, and review process. Collection of information involves the electronic submission of responses via Grants.gov.

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.

The information submitted in each application is unique to each respondent. Moreover, the information changes annually. No other existing information collection can serve the purposes described in item 2.

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.

Small businesses or small entities would not be impacted by this collection.

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.

This application will be used by those applicants that desire to apply for new awards under MSEIP. If this information is not collected, grants cannot be awarded in accordance with the guidelines outlined in the Title III, Part E legislation. If the collection were not conducted annually, appropriated funds could not be spent.

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.

There are no special circumstances that would require the collection to be conducted as outlined above in question 7.

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.

A notice for 30 day public comment will be published in the Federal Register. Program staff will respond to any questions or comments resulting from the publication of the information collection in the Federal Register as required by 5 CFR 1320.8(d).

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

No gifts or payments will be provided 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 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.

The Department’s disclosure policies adhere to the provisions of the Privacy Act and no assurances of confidentiality are provided.

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.

Questions of a sensitive nature are not included in this information collection.

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 in the ROCIS IC Burden Analysis Table. (The table should at minimum include Respondent types, IC activity, Respondent 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 Item 14.

Estimated burden hours for this collection of information are 40 hours per respondent and we estimate 200 respondents. Therefore, we expect an estimated total of 8,000 burden hours per annual submission.

We expect approximately 180 responses from public institutions and approximately 20 responses from private institutions. We estimate the cost per respondent for the burden to be $8,385. We estimate the cost for 180 applicants from public institutions to be approximately $1,509,300.00 and the cost for 20 applicants from private institutions to be approximately $167,700.00. The estimates provided are based on past experiences with the use of the form.

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

Total Annualized Capital/Startup Cost :      

Total Annual Costs (O&M) :      

____________________

Total Annualized Costs Requested :      

The total for the capital and start-up cost components for this information collection is zero. This information collection will not require the purchase of any capital equipment and will not create any start-up costs.

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.

Cost to the Federal Government
A professional staff to develop clearance package (Program Manager)	1 GS-14 employee: 60 hrs. @ $50 per hr.	$3,000
Overhead cost related to facilities, administration, and other indirect costs plus accrual of leave and fringe benefits	$3,000 x 50%	$1,500
Other Department staff to review and approve the request: GS-14 employees for final review and approval	3 GS-14 employees: 10 hours @ $50 per hr.	$1,500
Overhead cost – review and approval of clearance package	$1,500 x 50%	$750
Field Readers (Assuming 90 applications eligible to be read)	90 @ $1,100	$99,000
Processing applications by staff	3 staff x 40 hrs. x $40 per hr.	$4,800
Overhead cost – processing applications by staff	$4,800 x 50%	$2,400
Contractor logistical support for field reading trainings, application processing, field reading, and mailing technical review forms and letters		$40,000
Staff time for conducting supervised review	12 staff x 120 hrs. x $40 per hr.	$57,600
Overhead cost – conducting supervised review	$57,600 x 50%	$28,800
Staff time for generating slate	3 staff x $40 per hr. x 40 hrs.	$4,800
Overhead cost – Staff generating slate	$4,800 x 50%	$2,400
Review and approve funding recommendation	2 staff x 46 hrs. x $40 per hr.	$3,680
Overhead cost – review and approve funding recommendation	$3,680 x 50%	$1,840
Staff time to generate, approve, and issue grant awards	3 staff x $40 per hr. x 40 hrs.	$4,800
Overhead cost – staff time to generate, approve, and issue grant awards	$4,800 x 50%	$2,400
Annual monitoring cost	1 staff x 10 hrs. per award x 23 awards x $50 per hr.	$11,500
Overhead cost – staff annual monitoring cost	$11,500 x 50%	$5,750
Total Annual Government Estimated Cost		$276,520

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 reinstatement with change of a previously approved collection. Therefore, all burden is new.

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.

Results of the collected information will not be published.

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.

Not applicable. This report will display the expiration date for the OMB approval of the information collection.

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

Not applicable. 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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