2019_Supporting Statement for EOC APR FINAL

OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19

Annual Performance Report for Grants under the
Educational Opportunity Centers 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.
The Department of Education (Department) is requesting approval for an extension of the
Educational Opportunity Centers (EOC) Annual Performance Report (APR) that will
expire December 31, 2019 (OMB No.: 1840-0830). The EOC APR form is used to
collect annual performance report data from projects funded by EOC program grants.
The EOC program is a Student Service 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 the EOC program is
to help youth and adults from disadvantaged backgrounds complete secondary education
and enroll in programs of postsecondary education; and to publicize the availability of,
and facilitate the application for, student financial assistance for persons who seek to
pursue postsecondary education (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" 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 prior experience 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 prior experience points, based on data in the annual
performance report, 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 EOC 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 644, and the Education
Department General Administrative Regulations (EDGAR), in 34 CFR 74.51, 75.720,
and 75.732.
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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19

https://www2.ed.gov/programs/trioeoc/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 annual performance reports to produce programlevel 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 on 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
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. 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.
This information collection does not affect small businesses or other small entities.
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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19

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.

This information collection is conducted in a manner consistent with 5 CFR 1320.5(d)(2).
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,

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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19

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. We solicited public comments
on the draft package through a 60-day notice published in the Federal Register on May
2019 (84 FR 20867). A separate 30-day Federal Register notice, will be published to
solicit public comment on the APR form.
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. 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 that pledge of confidentiality should be provided. 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 the Department makes no pledge about the
confidentiality of the data.
No assurances of confidentiality are provided to the respondents. The Department makes
no pledge about the confidentiality of the data.
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.
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

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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19

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 a minimum include Respondent types, IC
activity, Respondent and Responses, Hours/Responses, 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 total annual burden hours for this collection of information is 1,120. We
estimate approximately 140 respondents annually. The performance reports are
submitted annually.
Estimated
Number of
Total estimated
Preparation Time,
Respondents
burden hours
per respondent
Public Sector
109
8 hours
872 hours
Private Sector
Total estimated
burden hours

31

8 hours

248 hours

140

8 hours

1,120 hours

(Estimated annual burden: 1,120 hrs. Total number of hours (preparation time) multiplied by
the total number of respondents equals estimated burden hours). Preparation time includes 7.5
hours for professional staff to gather the information using computerized technology and 0.5
hours for clerical staff to enter the data into the Web-based form.
Professional staff
(140 respondents X 7.5 hours X $35 per hour)
Clerical staff
(140 clerical staff members X 0.5 hours X $18 per hour)
Total estimated cost to all respondents

$36,750
$1,260
$38,010

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.)

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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19



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:
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.

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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Designing performance report form
120 hours at $40 per hour
Overhead (est. at 50%): 120 times $20
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

Revised: 4/2/19

$7,200
$7,200
$80,000
$90,000

$9,600
$194,000

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 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 statue, 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).
The statutory changes to the EOC program resulting from the Higher Education
Opportunity Act of 2008 (HEOA) and the FY 2016 EOC Notice Inviting Applications
allowed applicants to receive additional points in the FY 2016 EOC grant competition for
addressing the two Competitive Preference Priorities (CPPs). Two questions have been
added to the existing collection to allow grantees to report on the outcomes of the CPPs:
list community organizations and partners projects collaborate with during the
performance period, and number of military-connected subgroups served during the
performance period. The aggregated data that will be collected is being added. These
additional questions will not result in an increase of burden hours per grantee.
In addition, the number of respondents has decreased from 165 to 140, as a result of 25
projects not meeting substantial progress in FY 17, and therefore not receiving
continuation funding. Therefore, the number of projects currently completing the EOC
APR is 140 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 prior experience points. Performance

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OMB Number: 1840-0830
RIN Number: XXXX-XXXX (if applicable)

Revised: 4/2/19

measures and efficiency measures for the EOC program, based on data conveyed in
grantees' annual performance reports, 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.
B. Collections of Information Employing Statistical Methods
This collection does not employ statistical methods.

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