Supporting Statement Part A 1830-0569

Tracking and OMB Number: (XX) 1830-0569

Revised: 09/23/2021

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

1. Explain the circumstances that make the collection of information necessary. What is the purpose for this information collection? Identify any legal or administrative requirements that necessitate the collection. Include a citation that authorizes the collection of information. 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, list the sections with a brief description of the information collection requirement, and/or changes to sections, if applicable.

This is a request to renew and revise the information collection used by the U.S. Department of Education to gather annual reports from eligible agencies under the Carl D. Perkins Career and Technical Education Act, as amended by the Strengthening Career and Technical Education for the 21^st Century Act (Public Law 115-224) (Perkins V or the Act). Annual reports consist of narrative information, financial status reports (FSRs), and performance data pursuant to the Act and applicable Federal regulations pursuant to the Uniform Guidance (2 CFR 200) and Education Department General Administrative Regulations (2 CFR 76). Eligible agencies are the State boards, or sole State agencies, responsible for career and technical education in the 50 States; the District of Columbia; Puerto Rico; the outlying areas of the United States Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Marianas Islands; and the Republic of Palau.¹

Section 113(b)(3)(C) of Perkins V requires each eligible agency that receives an allotment under section 111 to annually prepare and submit to the Secretary a report regarding—

• the progress of the State in achieving the State determined levels of performance on the core indicators of performance described in section 113(b)(2) of the Act.

• the actual levels of performance for all career and technical education (CTE) concentrators, and for each of the subgroups of students, as described in section 1111(h)(1)(C)(ii)² of the Elementary and Secondary Education Act of 1965, and special populations, as described in section 3(48) of Perkins V.

Each eligible agency also must disaggregate data for each of the core indicators for the subgroups of students, as described in section 1111(h)(1)(C)(ii) of the ESEA, and special populations, as described in section 3(48), that are served under this Act; and (bb) by the career and technical education programs or programs of study of the CTE concentrators, except that in a case in which reporting by such program or program of study is impractical, the data may be disaggregated by the career clusters of the CTE concentrators, if appropriate.

As a recipient of Federal funds, each eligible agency must comply with the requirements for submitting annual performance reports to the Department pursuant to 2 CFR 200.328, including a comparison of actual accomplishments to the objectives of the Federal award and, if applicable, the reasons why established goals were not met.

Finally, as a recipient of Federal funds, each eligible agency must comply with the requirements for submitting annual financial reports to the Department pursuant to 2 CFR 200.327. To meet these requirements, an eligible agency must complete two separate forms, an interim FSR and a final FSR, each containing the same items. The interim FSR covers the first 12 and/or 15-month period for which the grant was awarded, while the final FSR covers the entire 27-month period for which the grant was awarded.

To enable eligible agencies to efficiently and effectively meet their annual reporting requirements, the Department has combined these reports into a single reporting instrument, the Consolidated Annual Report (CAR). Each eligible agency will submit its narrative performance report, FSRs, and performance data forms for the postsecondary core indicators to the Perkins Consolidated Annual Report (CAR) Portal at https://Perkins.ed.gov. Hard copies will not be accepted as the Department met the requirement of 2 CFR 76.720(b)93) for the transition from hard copy to electronic submission of CARs during the implementation of the Carl D. Perkins Career and Technical Education Act of 2006 (Perkins IV). The deadline for each eligible agency’s CAR submission is January 31 of the year following the most recently completed program year.

Each eligible agency must submit its performance data forms for the secondary core indicators to the Perkins CAR Portal as noted above.

This request to renew and revise the information collection used by the U.S. Department of Education to gather annual reports from eligible agencies under Perkins V contains the following changes:

• We are proposing to remove the option to report enrollment and performance data via the EDFacts system because the EDFacts office informed OCTAE that it was not able to update the necessary file specifications, obtain OMB approval and undergo the required public comment period in time for the upcoming January 2022 CAR. Last year, only two (2) of the fifty-three (53) Perkins grantees (States) elected to use the EDFacts system to report their Perkins Consolidated Annual Data. States overwhelmingly prefer to submit all their Perkins data via the Consolidated Annual Reporting portal (CAR).

• We are proposing to revise the Fiscal Responsibility section of the Narrative Performance Report (section II.B.2) to improve the quality of the fiscal information collected and to collect data that may be analyzed for the National Evaluation of Career and Technical Education under Perkins V. The revised instructions in II.B.2: (1) clarify that consortium members must be included as part of the subaward allocation information and (2) request actual subaward amounts. The Department is including an Excel template to assist States in submitting this information (see Secondary Subawards (Section 131) Form and Postsecondary Subawards (Section 132) Form).

• We are proposing to require that requests for extensions, amendments to FSRs, and amendments to performance data reports be sent to each eligible agency’s respective Perkins Regional Coordinator rather than to the Department’s CTE mailbox at cte@ed.gov.

• We are proposing to clarify in the Performance Data Reports Basic Reporting Instructions (section IV.A.1.a.i) that an eligible agency must report on all students participating in public CTE programs, meaning that a Perkins-funded eligible recipient must report on both its Perkins funded and non-Perkins funded public CTE programs, including those at public charter schools. Further, an eligible agency must report on all students participating in CTE at private agencies or institutions that receive Perkins funds.

We estimate that these changes will increase respondent burden by one hour per response.

The other changes in the estimated burden hours are the result of the implementation of the performance accountability requirements for Perkins V in FY 2021 and a change in the agency estimate to correct an error in the 2019 notice of action.

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 gathered through this package will be used in a variety of ways. First, narrative and financial information are reviewed by the Office of Career and Technical Adult Education (OCTAE), Division of Academic and Technical Education (DATE), to determine each eligible agency’s compliance with provisions of Perkins V and applicable Federal regulations as noted above. For example, eligible agencies are required to implement specific leadership activities in their State, as well as identify and quantify any disparities or gaps in performance on State determined performance levels between any disaggregated category of students and all CTE concentrators served by the eligible agency.

Second, DATE staff review performance data to determine whether, and to what extent, each eligible agency has met its State determined performance levels for the core indicators described in section 113(b)(2) of Perkins V. An eligible agency that did not meet at least 90 percent of the State determined performance levels for any of the core indicators described in section 113(b)(2) of Perkins V is required to develop and submit, as part of its CAR report, a program improvement plan with special consideration to the performance gaps identified under section 113(b)(2)(C)(ii)(II) of Perkins V. The improvement plan must address each core indicator(s) that a State failed to meet; disaggregated categories of students for which there were quantifiable disparities or gaps in performance compared to all students or any other category of students; steps that will be implemented, beginning in the current program year; staff members who are responsible for each action step; and the timeline for completing each action step. DATE staff will review these plans to determine whether they are thorough and appropriate in addressing the indicator(s) that were not met at the 90 percent level.

Third, Perkins V section 113(b)(3)(C)(iv)(III) requires the Secretary to provide the appropriate committees of Congress copies of annual reports received by the department from each eligible agency that receives funds under the Act. Section 113(b)(3)(C)(iv)(I) further requires the Secretary to make the information contained in such reports available to the general public. To meet this obligation, DATE compiles the CAR data into an annual report to Congress and makes the data available to the public online through the Peer Collaborative Resource Network (PCRN) at http://cte.ed.gov.

Fiscal data collected through the CAR also will be provided to the Institute of Education Sciences for analysis and use in the National Evaluation of Career and Technical Education under Perkins V.

Finally, DATE staff uses annual CAR information to determine which States will be monitored for an upcoming year or which States could benefit from technical assistance in particular areas. Annual CAR review results help in the identification of topics for annual Data Quality Institutes that DATE sponsors for eligible agencies, as well as the decision to offer customized technical assistance to States on accountability issues. This strategy has been well-received by the States and is deemed effective by our office in improving the reliability and validity of the Perkins data.

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. Please identify systems or websites used to electronically collect this information. Also describe any consideration given to using technology to reduce burden. If there is an increase or decrease in burden related to using technology (e.g. using an electronic form, system or website from paper), please explain in number 12.

Each eligible agency submits its report electronically via the Perkins CAR Portal (https://perkins.ed.gov/). This website allows an eligible agency to complete its reports using Web-based forms and to certify to the accuracy and completeness of its submission using electronic Personal Identification Numbers (PINs). It is important to note that the use of the PINs to certify and sign the CAR and FSRs is the same as certifying the documents with a hand-written signature by the State official. State officials are responsible for protecting the confidentiality of their PIN and for any use of their PIN by another individual.

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.

This is a unique collection; there are no similar data collections which seek this information.

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 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.

Without the information gathered through the CAR, the Department would be unable to determine whether, and to what extent, States were complying with the Perkins V legislation and applicable Federal regulations. Moreover, the Department would be unable to sufficiently review each State’s progress in meeting its performance levels and determine its own effectiveness in helping eligible agencies achieve the purposes of the Act. The Department also would be unable to comply with a statutory directive to report State performance data to the Congress and the public.

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.

The collection does not anticipate any such special circumstances.

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.

Include a citation for the 60 day comment period (e.g. Vol. 84 FR ##### and the date of publication). Summarize public comments received in response to the 60 day notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. If only non-substantive comments are provided, please provide a statement to that effect and that it did not relate or warrant any changes to this information collection request. In your comments, please also indicate the number of public comments received.

For the 30 day notice, indicate that a notice will be published.

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.

To determine the estimated burden hours associated with this collection, DATE staff consulted with State employees who will be responsible for compiling and submitting the CAR at nine eligible agencies.

Consistent with the Paperwork Reduction Act, the Department will publish two Federal Register notices to request public comment on this proposed revision and renewal of the CAR, one providing 60 days to comment and another that provides 30 days to comment. On July 23, 2021, the Department published the first Federal Register notice to request public comment (86 FR 39014). We received one set of comments. A summary of the comments and how we have addressed them by revising the ICR has been attached as a separate document. The Department is now publishing the 30-day invitation for public comments.

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

No payments or gifts will be provided 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.³ 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 confidentiality of the data. If no PII will be collected, state that no assurance of confidentiality is provided to respondents. If the Paperwork Burden Statement is not included physically on a form, you may include it here. Please ensure that your response per respondent matches the estimate provided in number 12.

The Department makes no pledge about the confidentiality of the data provided by respondents of this information collection. No personally identifiable information is collected; only State aggregate data is reported through this ICR.

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.

There are no questions of a sensitive nature contained in this information collection.

8. Provide estimates of the hour burden for this current information collection request. The statement should:

• Provide an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. Address changes in burden due to the use of technology (if applicable). Generally, estimates should not include burden hours for customary and usual business practices.

• Please do not include increases in burden and respondents numerically in this table. Explain these changes in number 15.

• 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. 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 this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burden in the table below.

• Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. Use this site to research the appropriate wage rate. 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. If there is no cost to respondents, indicate by entering 0 in the chart below and/or provide a statement.

Provide a descriptive narrative here in addition to completing the table below with burden hour estimates.

Estimated Annual Burden and Respondent Costs Table

Information Activity or IC (with type of respondent)	Sample Size (if applicable)	Respondent Response Rate (if applicable)	Number of Respondents	Number of Responses	Average Burden Hours per Response	Total Annual Burden Hours	Estimated Respondent Average Hourly Wage	Total Annual Costs (hourly wage x total burden hours)
2021 - Perkins V Consolidated Annual Report	N/A	100%	53	53	271	14,363	$64.02	$919,519
2022 – Perkins V Consolidated Annual Report	N/A	100%	53	53	222	11,766	$64.02	$753,259
2023 – Perkins V Consolidated Annual Report	N/A	100%	53	53	222	11,766	$64.02	$753,259
Annualized Totals	N/A	100%	53	53	238	12,632	$64.02	$808,679

Please ensure the annual total burden, respondents and response match those entered in IC Data Parts 1 and 2, and the response per respondent matches the Paperwork Burden Statement that must be included on all forms.

The 12,632 burden hours associated with this collection comprise the hours required by state officials to provide the student enrollment, fiscal, and student outcome data required under the Carl D. Perkins Career and Technical Education Act, as amended by the Strengthening Career and Technical Education for the 21^st Century Act. Our estimate of the burden hours is based upon our consultation with nine state officials in the agencies that respond to this ICR and their review of the forms and instructions. The increase in burden hours is the result of the implementation in FY 2021 of the new requirements of the Strengthening Career and Technical Education for the 21st Century Act, particularly the new performance reporting requirements, an administrative change to improve the quality of fiscal data collected, and a change in the agency estimate of burden to correct an error in the 2019 notice of action. One reason that burden hours increase in 2021 is because this is the first year that states are required to provide student outcome data required by the law. We estimate that the hours required to provide these data will be 271 in 2021 but 222 hours in subsequent years because the first year of reporting will require additional time to prepare agency data collection forms and systems. Another reason the burden hours increase is that we are proposing to collect data about subrecipients and the amounts of funds they receive under the law, principally so that these data may be analzed by the National Evaluation of Career and Technical Education under Perkins V that is being conducted by the Institute of Education Sciences. The remaining increase in burden hours is the result of our correction of errors in the notice of action when this ICR was approved by OMB in 2019. The burden hours included in the final supporting statement submitted to OMB were higher than the amount shown in the notice of action.

8. 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 :

There are no such costs to respondents.

8. 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 to implement this information collection is estimated at $52,310.80. This includes contractor beta testing and web site maintenance, and the salaries and expenses of DATE program staff who manage the process and review the CAR data. The method used to estimate the annual cost is as follows:

Program Office Staff:

1 GS-15 X 40 hours = $ 2,928.00

3 GS-14 X 80 hours = $ 13,885.20

2GS-13 X 80 hours = $ 8,425.60

Total Program Office Staff = $ 22,310.80

Contractor Staff = $ 30,000.00

ESTIMATED FEDERAL COST = $ 52,310.80

8. 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).

Provide a descriptive narrative for the reasons of any change in addition to completing the table with the burden hour change(s) here.

	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate
Total Burden	+1,725	+53	+9,558
Total Responses			-1
Total Costs (if applicable)	$260,488	+$3,393	+$544,798

Changes Due to Adjustment in Agency Estimate

The hours recorded in the NOA are incorrect and inconsistent with the hours and costs that were identified in the revised supporting statement submitted on May 15, 2019 and the document that responded to the 30-day public comments, both of which are in ROCIS and Reginfo.gov. In response to public comment, we revised our estimates of the burden hours and costs as follows:

Year	Estimated Number of Responses	Estimated Number of Burden Hours Per Response	Total Estimated Number of Burden Hours	Estimated Hourly Cost	Total Costs (Rounded to the Nearest .10)
2020	54	40	1,080	$59.23	$63,968.40
2021	54	270	14,580	$59.23	$863,573.4
2022	54	221	11,934	$59.23	$706,850.82
TOTAL		531	27,594		$1,634,392.62
3-Year Average		177	9,198	$59.23	$544,797.54

Thus, of the total burden hour increase of 11,318 hours, 9,558 hours are associated with the change in the agency estimate to reflect the correct number of burden hours associated with this collection. The increase in costs associated with the change in agency estimates is $544,798.

Additionally, the number of respondents is reduced from 54 to 53 because Guam has incorporated Perkins V into a consolidated grant award, but is not allocating these funds for career and technical education and is therefore no longer subject to the law’s reporting requirements.

Program Change Due to New Statute

Of the total burden hour increase of 11,318 hours, 1,707 hours are associated with the implementation of the new performance accountability and reporting requirements established by the Strengthening Career and Technical Education for the 21st Century Act. Eligible agencies were only required to report student participation and financial data during the 2020 reporting period. The hour burden is higher in 2021 than in subsequent years to account for the time required to change agency data collection forms and systems to reflect the provisions of the new law.

Program Change Due to Agency Discretion

Of the total burden hour increase of 11,318 hours, 53 hours are associated with the proposed revision of the Fiscal Responsibility section of the Narrative Performance Report (section II.B.2) to improve the quality of the fiscal information collected and to collect data that may be analyzed for the National Evaluation of Career and Technical Education under Perkins V. The revised instructions in II.B.2: (1) clarify that consortium members must be included as part of the subaward allocation information and (2) request actual subaward amounts. Based on our consultation with nine state eligible agency personnel, we estimate that the revision would increase the burden hours per response by one hour.

8. 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.

An annual report to Congress is prepared and published using the information collected in the CAR instrument. Enrollment and accountability data are also made available on the Department’s Perkins Collaborative Resource Network (PCRN) at cte.ed.gov. On the PCRN, interested parties can view data for individual States, as well as run customized reports with aggregated and disaggregated data on the students who participate and concentrate in CTE programs across the nation.

Below is the general schedule for production:

Task	Timeline
States submit CAR data	January 31 (deadline for reporting each year)
DATE staff review State’s CAR submissions	February 1 – April 15
States receive notification on the approval of their CAR submissions	April 15
DATE staff, in collaboration with contractors, tabulate data and prepare individual State profiles	April 15 – May 15
DATE staff develops draft report	June 15
DATE staff submits final draft report for Department clearance	July 1
DATE staff submits final report for Office of Communications and Outreach for final editing and printing	July 31
DATE staff submits final report to Congress	August 15

8. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not seeking this approval.

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

There are no exceptions to the certification statement identified in the Certification of Paperwork Reduction Act.

1 Under the prior Carl D. Perkins Career and Technical Education Act of 2006 (Perkins IV) legislation, American Samoa and the Northern Marianas Islands did not use Perkins funds for career and technical education as part of their consolidated grant awards under 34 CFR 76.125 through 76.137. Beginning in 2018, Guam incorporated Perkins into a consolidated grant award, but did not allocate Perkins funds for career and technical education. Accordingly, these entities are not included in the burden hour estimates in Item 12 of this statement.

2The subgroups identified in 1111(h)(1)(C)(ii) of the ESEA are: 1) each major racial and ethnic group; 2) economically disadvantaged students as compared to students who are not economically disadvantaged; 3) children with disabilities as compared to children without disabilities; 4) English proficiency status; 5) gender; and 6) migrant status], 7) homeless status, 8) status as a child in foster care, and 9) status as a student with a parent who is a member of the Armed Forces (as defined in section 101(a)(4) of title 10, United States Code) on active duty (as defined in section 101(d)(5) of such title).

3 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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