1840-0595Teacher Shortage Areas Support Statement122319(2-26-2020)

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 copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

This request is for approval of reporting requirements that are contained in the Federal Family Education Loan Program (FFELP) regulations (34 CFR 682.210) which address the targeted teacher deferment provision of the Higher Education Act of 1965 as amended by the Higher Education Amendment of 1986, sections 427(a)(2)(C)(vi), 428 (b)(1)(M)(vi), and

428 (b)(4)(A), which provide for the targeted teacher deferment.

The FFELP (34 CFR 682.210(q)), Paul Douglas Teacher Scholarship Program (34 CFR

653.50(a)), TEACH Grant Program, and Federal Perkins Loan Program (34 CFR 674.53(c)) regulations contain information collection requirements. The Chief State School Officers of each state provide the Secretary annually with a list of proposed teacher shortage areas for that state.

If a State does not submit the required written documentation proposing teacher shortage areas, FFEL/SLS and Federal Perkins Loan borrowers; Douglas scholars; and TEACH Grant recipients who teach in the state may not receive Federal program benefits to which they may be entitled.

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 information collected is necessary for a state to support its annual request for designation of teacher shortage areas within the state.

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.

Data is submitted electronically through a collection system using skip logic to reduce the burden for respondents.

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.

A single designated agency in each state is responsible for providing the targeted teacher shortage area proposal. There is no duplication of records that the state agencies must maintain.

5. If the collection of information impacts small businesses or other small entities (Item

8b of IC Data Part 2), describe any methods used to minimize burden.

The information collection has no significant impact on small businesses or the 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.

Loan borrowers, Douglas scholars, and TEACH grantees will not be able to receive the loan deferment, a reduction in teaching obligation, cancellation of their loan debt, or meet their teaching obligation if the teacher shortage area information is not collected from the state and designated by the Department.

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.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, 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.

Previously, we have consulted with the Chief State School Officers and have received their input on the requirements associated with this collection. Based on research conducted on the Teacher Shortage Areas data, in addition to reporting total shortage FTE in critical shortage areas, the Department is proposing to collect the shortage FTE by temporary certificate, out-of-subject area teaching, temporary certificate. Asking states to report by these categories will make the data comparable while maintain the right of states to declare shortages using data that is best representative of their states’ needs. Also, to prevent data from being artificially deflated and skewed, states are being asked to report every shortage and designate the ones that will be considered for federal assistance. We will publish the required 60- and 30-day Federal Register Notice seeking public comment.

A 60-day Federal Register Notice Vol. 84, No. 201 was published on October 17, 2019, seeking public comment. Two comments were received. One of the comments was irrelevant to the submission, the other comment was out of scope of the data collection. No changes will be made based on those comments. The Department will publish a 30-day Federal Register Notice for public comments.

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

Not applicable.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The information is not of a personal and confidential nature, and no assurance of confidentially is provided. The purpose of the collection is to designate teacher shortage areas and to distribute that information to loan administrative officials in the State Education Agencies.

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, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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 item 16 of IC Data Part 1.

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.

There is a total of 57 respondents to this annual information collection. The burden estimate for this information collection has decreased from 75.0 hours per respondent to 49.0 hours. The burden hours were calculated by determining the time to enter all types of data using an average of data entered for the past two years of electronic collection. Therefore, the total annual burden is calculated as follows:

49.0 hours x 57 respondents = 2793.0 hours

The hourly estimate includes identifying and collecting the relevant information, formatting and preparing the report response, securing appropriate signatures, and maintaining records.

The total annual cost burden to respondents is calculated as follows:

Professional Staff (49.0 hours at $33.00/hr) -------------- $1,617.00

Support Staff ($15.00/hr x 4.0 hours) $60.00

Estimated annual total cost for computer usage--------- $50.00

$1,727.00

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.

The total annual cost burden to respondents is $0

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 annual cost to the Federal Government for the State Teacher Shortage Area (TSA) proposals is estimated to be $8,100.00. This cost includes staff time in (1) preparing, emailing the solicitation for proposals; (2) reviewing the submissions by the

States; (3) recording and analyzing the information and methods used to determine the TSA. This step is necessary to ensure state compliance with the program statute and regulations; and (4) preparation and posting of the updated information of TSA on the Office of Postsecondary Education web pages.

The annual costs to the Federal government are calculated as follows:

Professional Staff (150 hrs x $50.00)----------------------- $ 7,500.00

Support Staff (5 hrs x $20.00/hr)----------------------------- $ 100.00

Computer time, Miscellaneous (emailing) ----------------- $ 500.00

Total estimated cost to the Federal Government-------- $8,100.00

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data

Part 1 Form.

The decrease in burden is the result of the online data collection with preloaded data and skip patterns to remove unnecessary question items.

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 are not intended for statistical use.

Letters to the Chief State School Officer designating federal teacher shortage areas are insured, with copies distributed to several state contacts. Thereafter, a nationwide list of teacher

shortage areas are published by the Department and distributed to TSA contacts in each state, state Douglas program officers, and CEOs of the state guarantee agencies as well as posted on the Department of Education website.

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 expiration date for OMB approval of the information collection will be displayed on the form.

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

Paperwork Reduction Act.

There are none.

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