August 30, 2010
Supporting Statement for the Reporting Requirements for the Charter Schools Facilities Financing Demonstration/Credit Enhancement for Charter School Facilities Program
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.
The Credit Enhancement for Charter School Facilities Program and its virtually identical antecedent program, the Charter Schools Facilities Financing Demonstration Program, authorized as part of the reauthorization of the Elementary and Secondary Education Act, to have a statutory mandate for an annual report (respectively, Section 5227 and Section 10227). This reporting is a requirement in order to obtain or retain benefits according to section 5527 part b of the Elementary and Secondary Education Act of 1965.
All grantees must provide the following on an annual basis:
A. The grant performance summary page. This page provides key summary data related to the performance of the grant;
B. An evaluation by the grantee
of the effectiveness of its use of Federal funds to leverage other
funds. This evaluation must include a description of the activities
used to assist charter schools in acquiring (by purchase, lease or
donation) or constructing (including renovating, repairing, and
altering) school facilities and a description of the characteristics
of lenders and other financial institutions participating in the
activities undertaken by the grantee. Furthermore, it must (1)
include a statement about whether the grantee has sufficient
resources from its grant to serve additional schools, (2) an
approximate number of how many additional schools it can serve within
12 months, and (3) indicate the amount of grant funds available,
including the amount of grant funds that are anticipated to be
recycled within the next 12 months. In the event that the there have
been any delinquencies or defaults, the grantee must identify the
school(s) and remedies, and indicate both draws from and
reimbursements to the reserve account. In the event that there has
been a notice of probation, suspension, or revocation of a charter,
the grantee must elaborate. In the event there was collaboration
with another grantee to serve one or more charter schools, the
grantee must indicate the names of the schools and the grantees;
C. A budget report including actual and
projected expenditures. In addition, the report must include a brief
narrative describing the uses of the actual expenditures;
D. A timeline that includes specific
schedules and accomplishments pertaining to the Grantee’s
program.
E. An IRS Form 990 (due 30 days after filing);
F. An audit report (including any opinion
thereon); the OMB Circular A-133 audit; and audited financial
statements, including (1) the management letter and any response(s);
(2) schedules; and (3) auditor’s notes related to the specific
activity for which the Grant money was awarded, (due 180 days
following the end of the Grantee’s standard fiscal year);
G. The EXCEL spreadsheet. The EXCEL
spreadsheet includes the Newly, Previously, and Leases workbook, the
Budget workbook, and the Reconciliation workbook;
H. Bank or brokerage statement(s) for all reserve account investments and deposits as of the last day of the reporting period or as close to that date as possible. There is no need to submit statements for every month of the year.
Furthermore, grantees that use their grants to credit-enhance loans that they (rather than a third party) make must provide copies of the term sheets for charter schools served under this grant as part of these reports. In addition, grantees that guarantee or insure leases of a building(s) that they own must submit a copy of the lease and the terms and conditions of the guarantee of the lease.
Performance indicators
The performance indicators include:
The amount of funding grantees leverage for charter schools to acquire, construct, and renovate school facilities and
The number of charter schools served.
Unlike other discretionary grant programs administered by ED, this program is primarily a financial program. These grantees draw down the entire amount of their grants after they sign a performance agreement acceptable to ED. All grantees must invest grant funds and use these monies to leverage non-Federal funds for the purchase, renovation, or construction of facilities by guaranteeing, insuring, reinsuring debt and leases. Monitoring these grants is critical to ensure that funds are properly invested, funds are properly spent or otherwise applied, and the grantees perform up to the level they committed to in their performance agreements. Used properly, the funds should serve multiple charter schools and, over time, be recycled to help additional schools, thus extending these project grantee periods for approximately 30 years.
OMB clearance is requested for the entire annual report as the number of respondents exceeds 9.
To simplify reporting for the grantees, ED has divided the attached EXCEL spreadsheet into three workbooks: 1) Newly, Previously, and Leases; 2) Budget; and 3) Reconciliation. Each section is explained below. The information obtained in these annual reports would be used to monitor grantee performance.
Newly, Previously, and Leases: This section includes basic school identifiers that reveal what types of schools and students have been served with program funds. In addition, this section requests specific information regarding the financings, to assist ED in determining if the program provides better rates and returns than the schools would be otherwise able to obtain. Information provided in this section will also identify any defaults or other problems tied to repayments, and how the grantee has used grant funds to remedy such situations. This section requires details regarding the resulting facilities for each school (purchase, construction, and renovation details) and how such facility improvements and/or acquisitions may have enabled the schools to accommodate more students. Finally, while grantees primarily focus on guaranteeing and insuring debt, we also seek to capture uses of funds for the other three statutory purposes of the program: guaranteeing and insuring leases, facilitating lending, and facilitating bonding.
Budget: Since all of the grantee’s projects last for longer than the five years budgeted in the performance agreement, we seek to update these budgets, as well as to collect data on actual expenditures and earnings.
Reconciliation: This section would have grantees reconcile the balances for their reserve accounts. This grant program is unusual in that grantees may drawdown their entire grant without actually spending these funds. In addition, these grants can both increase in size through earnings on the grant funds and decrease in size due to defaults and other types of grant expenses. The reconciliation workbook would help track these grant funds and decrease the ability of someone to misstate grant expenses or improperly use these funds.
Lastly, grantees would include a summary page that would provide cursory quantitative information about the grantee’s performance. We require grantees to submit their most recent performance report as part of their grant application. The grant readers and ED’s evaluation office indicate that including this page would make it easier for them to judge the performance of the grantees.
Proposed Changes:
This is the second time the US Department of Education (ED) has changed the performance report for the Credit Enhancement for Charter School Facilities Grants program. ED is proposing to make several changes to both minimize the paperwork burden it imposes and to maximize the utility of the data collection.
Annual report items
Within the Performance Report Summary Sheet, ED proposes to add four questions.
ED proposes to add “Amount of grant funds available to serve additional charter schools, as of today”, “Amount of grant funds anticipated to be recycled within the next 12 months”, “Approximate number of additional schools serviced within the next 12 months”, and “Number of total transactions service under the grant since the inception of the grant project”. The addition of the first three questions will provide a better reflection of the work that the grantees will conduct in the future years. This information is helpful for grant readers and ED’s evaluation office to make it easier to judge the performance of the grantees. The fourth question is included, at the request of the grantees, to provide a more accurate count of the number of transactions conducted with the grant funds rather than only reporting the number of the charter schools served with the grant funds. It provides a more complete picture of all the work the grantees have done.
Within the Excel spreadsheet, ED proposes to combine three of the workbooks that used to be required and add a summary table, five additional questions, and combined eight questions into three questions by utilizing a drop down menu.
ED proposes
to combine the Newly financed schools workbook, Previously financed
schools workbook, and Schools receiving services other than
guaranteeing or insuring debt workbook. The combined workbook would
make it easier to reconcile and capture all schools served on one
workbook. Combining all three workbooks into one would also ensure
that the data matches the information provided in the summary table.
In reviewing previous annual performance reports, ED staff noticed
the Performance Report Summary Sheet did not correctly match the
data in the Excel files. By having a summary table above the
listing of all transactions, it should help to ensure the supporting
data is accurate.
ED proposes to add a summary table to the Newly, Previously, and Leases workbook. The summary table would provide a quick overview, by year, of the loan amount leveraged, amount of loans directly credit enhanced, number of new schools served, and number of new schools served. The workbook will also provide a running total, of these four categories, throughout the life of the grant. ED proposes to add five new questions: (1) Year School served, (2) Type of Transaction (dropdown), (3) Name of Bank or Banks Providing the Financing, (4) What was the benefit of the Credit Enhancement? and (5) What happened to the school after the credit enhancement expired? These additional questions will help with the accuracy of the reporting information and capture the information that has not been previously collected. Grantees requested the addition of questions four and five and indicated these additional questions would not be difficult to report.
ED proposes to combine several questions into one question, using the dropdown function in Excel. There are three questions in the newly proposed Excel that would combine several questions from the previously approved Excel file. The new questions “How the financing was used?” would be a new dropdown that would combine three questions from the previous Excel. The new question “Was financing for an addition, an existing building, or a new building?” would be a new dropdown that would combine two questions from previous Excel. The new question “How was the school served?” would be a new dropdown that would combine three questions from previous Excel. Combining these questions should make it easier for the grantee to select the appropriate answer to the questions and lessen the burden to the grantee.
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 reports will be used to monitor grantees for compliance with their performance agreements and the statutory and regulatory requirements for the program. The reports will also be used to evaluate and improve the performance of the program. Furthermore, the reports will be used by the Secretary to report to Congress required under Section 5227(b)(3)/10227(b)(3).
In addition, past performance reports must be added to the application package for the program (1810-0644) since past performance is a factor under the selection criteria for previous grant recipients.
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 Department plans to accept electronically submitted performance reports in Word and Excel.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The annual performance report is intended to serve a specific authorized purpose and is in keeping with statutory requirements. Without this data collection, the statutory requirement cannot be met.
The information supplied by the grantees is unique to this program and the particular grantee. Each grantee is required to submit an annual performance report that details its activities under the Credit Enhancement for Charter School Facilities Grants Program. The information collected in the annual performance report is not collected by other data collections or sources.
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.
Small businesses are not impacted by this data collection.
6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
The Department needs the information to monitor and evaluate grantees. If no
information were collected, the Department would not be in compliance with the
authorizing statute and the application notice. In addition, the Department would not be
able to report on its GPRA performance indicators for the program. Data collection is
also critical in these grants to ensure that these multi-millionaire grants are appropriately
handled.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
requiring respondents to report information to the agency more often than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.
There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5.
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.
The Department held a meeting with grantees to discuss changes to the annual performance report. The Department discussed proposed changes and provided an opportunity for grantees to recommend additional changes. Specifically, the grantees indicated it would be helpful for the Department to ask specific questions regarding the benefit of the credit enhancement grant funds and what happened to the school after the credit enhancement grant funds expired. The grantees felt these questions would capture the importance of the credit enhancement grant funds.
We sought public comment via the 60 day Federal Registrar notice published on July 14, 2010, Vol. 75, Page 40796. No public comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No gifts or payments will be made to respondents other than the award to the grant
recipient.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
No assurance of confidentiality is provided.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There is no question of a sensitive nature in this collection of information.
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.
We estimate respondent cost at an average of $30 per hour so that the average cost per annual report would be $30 x 25 hours = $750.
We expect that a total of 30 annual reports will be received from grantees. Total estimated cost: $22,500.
Estimated data burden for grants:
Annual reporting burden per response (preparing and submitting the annual report):
25 hours x 30 grants = 750 hours
Total Burden for Grant = 750 hours
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.
Total Annualized Capital/Startup Cost : $ .00
Total Annual Costs (O&M) : .00
____________________
Total Annualized Costs Requested : $ .00
There are no startup costs to respondents.
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.
Estimated annualized Federal cost:
The salary of the staff that will be conducting the reviews is higher than previously reported and therefore the estimated annualized Federal cost has increased. Currently, the Department has two employees working on this program so this change is reflected in the below calculation.
Program Personnel:
1 person @ $30/hr. x 300 hours = $9,000
1 person @ $44/hr. x 300 hours = $13,200
15. Explain the reasons for any
program changes or adjustments to #16f of the IC Data Part 1 Form.
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.
The Secretary will use the results to report to Congress and in reporting data under the
Government Performance and Results Act.
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 information collection.
18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.
There is no exception to the certifications.
Statistical Methodology
This collection does not employ statistical methodology.
| File Type | application/msword |
| File Title | The Charter School’s Facilities Financing Demonstration Program, authorized in 2001 under the reauthorization of the Elementar |
| Author | Mullan, Kate |
| Last Modified By | #Administrator |
| File Modified | 2010-09-21 |
| File Created | 2010-09-21 |