60D Comment Response Summary

Paperwork Reduction Act Submission Supporting Statement

Formula Grant EASIE Electronic Application System for Indian Education

October 2020

Response to Public Comments

The Department of Education (ED) solicited comments on a proposed revision to Formula Grant EASIE Electronic Application System for Indian Education, an existing information collection, in a notice published in the Federal Register on August 21, 2020 (85 FR 51684). We describe and respond to these comments below. The commenters were broadly appreciative of the efforts made by ED to prepopulate data, update application forms, and provide an electronic application process that is easy to use. ED received a total of 11 public comment submissions. Of those, nine submissions provided specific substantive comments to which we respond below. Eight commenters identified themselves. Nine parties submitted comments on information collection. Comments from two parties were unrelated to the information collection and therefore were not addressed. OIE has provided responses to the other seven commenters who were representatives of LEAs and provided suggestions related to the following six topics: electronic signatures, simplifying the application, carry-over funds, parent committee requirements, timing, and public review of application changes.

Background:

The Indian Education Formula Grant (CFDA 84.060A) program provides grants to local educational agencies (LEAs), Indian Tribes, Indian organizations (IOs), and Indian community-based organizations (ICBOs) to develop and implement elementary and secondary school programs that serve Indian students. ED funds programs that are designed to meet the unique cultural, language, and educational needs of American Indian and Alaska Native students and ensure that all students meet challenging State academic standards. Funds must be used to carry out a comprehensive program for Indian students and must supplement the regular school program. The Indian Education Formula Grant requires the annual submission of the Electronic Application System for Indian Education (Formula Grant EASIE) through an online portal hosted on Federally managed and secured computer systems.

public comments and responses

1. Electronic Signatures

Comments:

Two commenters asked that electronic signatures be permitted for the ED 506 form. An additional commenter asked that electronic signatures be permitted for the parent committee form.

Response:

The ED 506 form and parent committee approval form are now electronically fillable and can be accessed on the EASIE Community of Practice website. Applicants are permitted to collect signatures electronically and should follow State and local laws and procedures concerning electronic signatures to ensure valid and authentic signatures. Each state has its own procedures for ensuring that electronic signatures are valid and authentic. ED has recommendations for security measures, such as 2-factor authentication, in addition to following state and local laws/policies on electronic signatures.

2. Simplifying the Application

Comments:

Three commenters provided suggestions related to simplifying the application. All three commenters asked that ED consider streamlining the application form. Two of the commenters also asked that examples [of the new application and platform?] be provided. One of the commenters stated that they are a very small LEA and the application is overwhelming for a district of their size.

Response:

Each year we look for ways to streamline and simplify the application process and forms. We believe the new proposed application and platform does significantly simplify the process for all grantees. We will continue to review not only our application forms but all our processes to support the different types of grantees. The OIE Formula Team and the Partner Support Center (PSC) are always eager to support new and returning grantees applications.

3. Parent Committee Requirements

Comments:

One commenter asked that ED consider whether the parent committee can be required to have copies of bylaws, agenda for meetings, and minutes to verify meetings for parent input.

Response

Local educational agencies (LEAs) are required to develop their program with the participation and written approval of an Indian parent committee. (ESEA section 6114 (c)). That committee must adopt reasonable bylaws to govern the conduct of the activities of the parent committee. (ESEA section 6114(c)(4)(D)). Meeting agendas, meeting minutes, and document retention policies may be governed by the bylaws, or other local or State policies or open meeting laws.

4. Timing

Comments:

One commenter noted that the ED 506 form should be available earlier than the Fall. They noted that the Fall is too late for LEAs as enrollments have already started by that time.

Response:

OIE appreciates the commenter’s request; please note that the ED 506 form is available on the EASIE Community of Practice site throughout the entire year. ED 506 forms can be collected by the applicant on a rolling basis. Students who were enrolled on the count date, and for whom there is a valid ED 506 form on file, should be included in the student count.

5. Public Review of Application Changes

Comments:

Two commenters asked that ED show the changes to the application from one OMB package to the next to make it easier for potential applicants to see, and therefore prepare for, the changes.

Response:

ED made the updated versions available at the beginning of the 60-Day Comment Period via the Federal Register link(s). The updated versions include the changes to the application package. Those documents will be provided again during the upcoming follow-up 30-Day Comment period.

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