OMB_Package_RTTT_Supporting_Statement_09-1015

Race to the Top Application for Initial Funding:

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification

A.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.

On February 17, 2009, President Barack Obama signed into law the American Recovery and Reinvestment Act of 2009 (ARRA), historic legislation designed to stimulate the economy, support job creation, and invest in critical sectors, including education. The ARRA lays the foundation for education reform by supporting investments in innovative strategies that are most likely to lead to improved results for students, long-term gains in school and school system capacity, and increased productivity and effectiveness.

The ARRA provides $4.3 billion for the Race to the Top Fund (referred to in the statute as the State Incentive Grant Fund). This is a competitive grant program designed to encourage and reward States that are implementing significant education reforms across the four “assurance” areas. Specifically, section 14006(a) (2) of the ARRA requires States to have made significant progress in the following four education reform areas in order to receive a grant: implementing standards and assessments, improving collection and use of data, improving teacher effectiveness and achieving equity in teacher distribution, and supporting struggling schools. In addition, as required by section 14006(c) of the ARRA, States that receive a Race to the Top grant must used at least 50 percent of the award to provide subgrants to local educational agencies (LEAs), including public charter schools identified as LEAs under State law, based upon LEAs’ relative shares of funding under Part A of Title I of the Elementary and Secondary Education Act of 1965, as amended (ESEA). LEAs that choose to participate in their State’s Race to the Top proposal must use their funding under this grant to support the State’s plan, as set forth in agreements between the State and participating LEAs.

In order to allow for the Race to the Top grants to be awarded in two phases, we are committed to expediting the application for Race to the Top, necessitating emergency clearance of the application.

A.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 in the form of a single application submitted by States. A State must submit to the Department an application that provides the following information:

Race to the Top Application Assurances that include the signature of the Governor or authorized representative. (Part III of the Application)

Assurances: Accountability, Transparency, Reporting Assurances and Other Assurances and Certifications. (Part IV of the Application)

Progress and Plans in the Four Education Reform Areas. (Part V of the Application)

Competition Priorities (Part VI of the Application)

Budget Part I: Summary Table

Budget Part II: Narrative

Indirect Costs.

This is a new collection. The Department will use a two-tiered review process to judge the eligible applications. The initial tier will consider only the applications submitted by the States; the finalist tier will consider both applications and in-person presentations. In both tiers, the Department will use independent reviewers who have been chosen from a pool of qualified educators, policymakers, scholars, and business leaders. All reviewers will be thoroughly screened for conflicts of interest to ensure a fair and competitive review process.

A.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 of using information technology to reduce burden.

The information requested under this collection will be gathered by email, fax, or other non-electronic means such as courier or postal service. The Department is considering employing other electronic means, such as e-application, if time allows given the the short timeframe of this application process. The employment of electronic means such as an online grants application or data warehouse would require additional time to set up the appropriate structure. The Department expects no more than 52 applications under this collection, and therefore has sufficient capacity to deal with the number of email or paper-based submissions but may employ other electronic means such as e-applications if this proves to be feasbile . The information gathered through this process is detailed in A2.

A.4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use of the purposes described in Item 2 above.

The assurances and information requested under this collection are unique to the Race to the Top program, and the Department has not collected them in the past. Even in the event of similar or comparable information for other programs in the past, the assurances are specific to the Race to the Top program and the information is specific to the present point in time. Therefore, any comparable information and assurances that were collected in the past would not satisfy the requirements for this program.

The Department has made every effort to reduce the burden on States in producing the information. Where applicable, States may use existing data sources that the Department has on file. In addition, of the eight selection criteria for which performance measures are possible, the Department has made four of the measures optional.

A.5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The Secretary certifies that this proposed action will not have a significant economic impact on a substantial number of small entities. The Secretary makes this certification because the only entities eligible to apply for grants are States and States are not small entities.

A.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 consequence of not conducting the collection of information under the Race to the Top program application process would be that States would not be able to receive Race to the Top funds and the program could not be implemented. The Department must conduct this collection in order to award all program funds by September 30, 2010. The Department would be out of compliance with the Stabilization provision of ARRA if it does not conduct this information collection.

The Department intends to award funds in two phases beginning in Spring 2010. The requested emergency clearance will provide time for Phase 1 awards to be made so that States that are not successful will receive feedback and may revise and resubmit prior to the Phase 2 application deadline.

A.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 which 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 collection is consistent with 5 CFR 1320.5.

A.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.

Although this collection will be submitted under emergency processing, the public will have an opportunity to comment during this emergency processing. Since this is an ARRA-related emergency collection and there is an immediate need to make applications available, ED is requesting that the comment period be waived. However, a 60-day comment period will be offered during a regular collection review. The Department does not anticipate significant changes to the application package between the two phases of the competition.

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

No payments or gifts to respondents have been made.

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

There is no assurance of confidentiality.

A.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.

A.12. Provide estimates of the hour burden of the collection of information.

A. Burden hours for respondents

The Department estimate that each SEA would spend approximately 681 hours of staff time to address the application requirements and criteria, prepare the application, and obtain necessary clearances. The total number of hours for all 52 SEAs is an estimated 35,412 hours (52 SEAs (the 50 States plus the District of Columbia and Puerto Rico) times 681 hours equals 35,412 hours.) We estimate the average total cost per hour of the State-level staff who carry out this work to be $30.00 an hour. The total estimated cost for all States would be $1,062,360 ($30.00 X 35,412 hours = $1,062,360).

A. State Success Factors	Hours
(A)(1) Articulating State’s education reform agenda and LEAs’ participation in it	60
(A)(2) Building strong statewide capacity to implement, scale and sustain proposed plans	80
(A)(3) Demonstrating significant progress in raising achievement and closing gaps	80
B. Standards and Assessments
(B)(1) Developing and adopting common standards	8
(B)(2) Developing and implementing common, high-quality assessments	8
(B)(3) Supporting the transition to enhanced standards and high-quality assessments	15
C. Data Systems to Support Instruction
(C)(1) Fully implementing a statewide longitudinal data system	3
(C)(2) Accessing and using State data	15
(C)(3) Using data to improve instruction	50
D. Great Teachers and Leaders
(D)(1) Providing alternative pathways for aspiring teachers and principals	15
(D)(2) Improving teacher and principal effectiveness based on performance	60
(D)(3) Ensuring equitable distribution of effective teachers and principals	40
(D)(4) Reporting the effectiveness of teacher and principal preparation programs	15
(D)(5) Providing effective support to teachers and principals	30
E. Turning Around the Lowest-Achieving Schools
E. Turning Around the Lowest-Achieving Schools
(E)(1) Intervening in the lowest-achieving schools and LEAs	15
(E)(2) Turning around the lowest- achieving schools	45
F. General Selection Criteria
(F)(1) Making education funding a priority	45
(F)(2) Ensuring successful conditions for high-performing charters and other innovative schools	35
(F)(3) Demonstrating other significant reform conditions	0
(F)(4) Implementing other significant reform plans	0
Application Requirements
(a) Required signatures	12
(b) Progress in the four education reform areas (as described in Selection Criterion (A)(3)(i))	n/a
(c) The State’s proposed budget (as described in Selection Criterion (A)(2)(i)(d)), including how it will (1) Achieve its targets (as described in Selection Criterion (A)(3)(iii)) and (2) give priority to high-need LEAs	10
(d) Required information for State Reform Conditions Criteria	n/a
(e) Required information for Reform Plan Criterion	n/a
(f) Attorney General certification	40
(g) Subgroup guidance	n/a
Total	681

B. Cost to Respondents

The Department estimates that the per-hour cost at State level will average $30 per person (approximately GS-12 equivalent) hour for a total of $1,062,360 (= 681 hours x $30 x 52 respondents).

A.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 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.

Total Annualized Capital/Startup Cost: 0

Total Annual Costs (O&M): 0

_________________________________________

Total Annualized Costs Requested: 0

There are no start-up costs for this collection.

A.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 Federal costs will involve screening the applications, managing the grant review, and awarding Race to the Top funds to States. Calculations include the two phases:

• Grade 13: 2,240 hours at $43.04/hour = $96,409.60

• Grade 14: 250 hours at $50.86/hour = $12,715

• Grade 15: 350 hours at $61.76/hour = $21,616

The Department plans to award a contract for assistance with the application review. The value of the grant review is expected to be approximately $2 million. The calculation includes the review costs associated with both phases of the Race to the Top competition. The total includes costs for meeting space for the review, contractual support, conference calls, printing, and mailing expenses, computer and printer rental, reviewer expenses (travel, lodging, honoraria, etc.).

A.15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

This is a new collection related to a new program.

A.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.

Some of the information collected in this grant application may be analyzed with performance data and shared on a government website such as recovery.gov or ed.gov.

A.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 will be displayed on the form.

A18. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

The Department is requesting an exception to the provision certifying a reduction in burden for small entities because the provision does not apply. The Secretary has certified in A.5. (above) that this proposed action will not have a significant economic impact on small entities because the only entities eligible to apply for grants are States and States are not small entities. Additionally, the provision for certifying the use of effective and efficient statistical survey methodology does not apply to this proposed action.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This information collection does not employ statistical methods.

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