OMB supporting statement 2023 APR 11.2.23 FINAL

OMB Number: 1840-0777 Revised: 11/2/2023

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

     

A. Justification

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.

Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP), created in the Higher Education Amendments of 1998 (Title IV, Section 404A-404H), is designed to raise educational expectations and strengthen preparation for college for low-income middle grade and secondary school students through competitively awarded grants to state projects and local partnerships. Grantees (states and local partnerships) provide services including tutoring, mentoring, academic enrichment, student and family support, dissemination of information to students and their parents about postsecondary education and options for financing college, and financial assistance.

The regulations governing the Gaining Early Awareness and Readiness for Undergraduate Programs are 34 CFR Part 694. The Education Department General Administrative Regulations (EDGAR) requires grantees to submit a final performance report - see 34 CFR Part 74.71 and 34 CFR Part 80.50 (http://www2.ed.gov/programs/gearup/legislation.html).

The Annual Performance Report (APR) is prepared and submitted by GEAR UP grant recipients around the month of April. The information collected in the Annual Report allows the Department of Education (ED) to determine if a GEAR UP grant project is ready to proceed to the next year in “good standing” or needs further departmental post award action. Each grantee’s Annual Report must communicate or substantiate that the goals of the GEAR UP grant program were achieved. This report is a means for grantees to share the overall experience of their projects and document the achievements and concerns, and describe the effect of their projects on participants being served; project barriers/ “lessons learned” and successes/major accomplishments; and evidence of sustainability.

The Annual Report is used by the Department to determine whether recipients of discretionary grants have made substantial progress towards meeting the objective of their respective projects, as outlined in their grant applications and/or subsequent work plans. In addition, the annual report enables the Department of Education to evaluate each grant project’s fiscal operations annually for the grant performance period, and compare the total expenditures relative to federal funds awarded, and actual cost-share/matching relative to the total amount in the approved grant application.

Furthermore, the GEAR UP Annual Report is used to collect data addressing the performance of the program on a national level and thereby includes the information for the Department to use when reporting the program implementation, student outcomes, and other required data on the GEAR UP Government Performance and Results Act of 1993 (GPRA) performance indicators.

The current Program Performance Annual Report for the GEAR UP Program (OMB No. 1840-0777) will expire on August 31, 2025. This submission requests to revise the APR in several places, with updated questions on a number of subjects, including project financial status, scholarship program, participant demographics, project services, and participant outcomes.

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 Annual Report is completed by each GEAR UP grantee annually. The Department will use the data collection to ensure compliance with the performance goals and program requirements of GEAR UP.

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.

The Annual Report has been converted to a computer-based application. The data collection can now be submitted, signed, filed, completed and conducted electronically through a website developed for ED by The Tactile Group., at the following address: https://gearup.ed.gov/ .

Grantees access the report by entering their unique ID and password. They can save their report by sections and submit the report to ED once completed. There are also edit checks on the number of students served and automatic totaling of budget information to avoid typographical and computational errors. These changes prevent submission of incomplete and erroneous reports.

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.

GEAR UP’s Annual Report is the primary method to collect the overall programmatic and fiscal information from the entire performance period of a project grant, and thereby serves as a GEAR UP grantee’s culminating report. The Annual Report collects data on the total federal expenditures and in-kind and matching contributions for each individual year of the project grant. The report serves as the recipients’ means to communicate the accomplishments of their projects to determine the impact on the beneficiaries (primarily students), and to display clear evidence of making substantial progress toward achieving the program goals and meeting their proposed project objectives. Furthermore, the Annual Report is GEAR UP’s primary method to collect and analyze data on the high school graduation and immediate postsecondary education enrollment rates of the students served by the GEAR UP program.

Since the information submitted is specific to the GEAR UP program, there is no duplication. There is no other data collection instrument available that is critical to meet the purposes described in Items 1 and 2 above.

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.

We continue to anticipate that no small entities will be required to complete this annual performance report. The collection of this information has no impact on 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.

In accordance with EDGAR, 34 CFR §74.71 (institutions of higher education) and §80.50 (state and local governments), and other ED Discretionary Grants policies, an annual program performance report must be submitted by each recipient in April.

The Department of Education cannot close out a grant award unless it determines that all of the required work of the grant has been completed. The annual program performance report serves to provide such evidence, and convey the extent to which a grant recipient (a) achieved the overall goals of the GEAR UP grant program; (b) implemented the proposed (as indicated in the approved proposal or subsequent work plan) services/activities, met the project’s supporting objectives, and reported information that demonstrates successful achievement of expected grant project outcomes; and (c) with respect to fiscal operations, expended all of the federal funds obligated, and contributed the proposed in-kind and financial resources (cost-share/matching) on a yearly basis.

It is critical for GEAR UP grantees to submit their Annual Reports in a timely manner so that the Department can determine if a grant project is ready to continue to the next year in “good standing.” If the grant recipient’s report has not been received or the information in the report does not demonstrate successful achievement of expected outcomes, an ED staff person must follow up with the particular recipient. It must be determined in the follow-up if an oversight occurred, or if the recipient did not meet the grant project’s proposed objectives, and/or if the recipient complied with the GEAR UP program requirements and reporting responsibilities (once a grant project ends).

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.

Respondents will be required to retain records for more than three years. No other special circumstances apply.

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.

The Department published a 60-day Federal Register notice as required by 5 CFR 1320.8(d) on August 29, 2023, to solicit comments on the information collection prior to submission to OMB. Two comments were received. The Department has reviewed and responded in writing to these comments.

A separate 30-day Federal Register notice will be published to solicit public comment on the APR. The Department will summarize public comments received in response to this notice and describe actions taken by the agency in response to these comments.

9. 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 are provided to respondents.

10. 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.¹ 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.

Annual Report data will not be confidential. The report does not collect data in which individual students can be identified.

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.

The questions are not of a sensitive nature.

12. 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)
Public	N/A	N/A	37	37	20	740	$30/hour	$22,200
Private	N/A	N/A	122	122	20	2,440	$30/hour	$73,200
Annualized Totals	x	x	159	159	x	3,180	x	$95,400

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.

We estimate that it will take 159 respondents 3,180 total hours to complete and submit the form.

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. 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 :

The only costs would be for customary and usual business practices.

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.

Activities/Task	Cost	Hours	Number of Reports	Total Cost to Fed. Govt.
Annual Report revisions/form design once every 3 years	$45/hr	40		$1,800
Securing OMB approval once every 3 years	$45/hr	40		$1,800
GEAR UP staff reviewing Annual Reports	$45/hr	4 hrs/APR	159	$28,620
Technical assistance to grantees (pre and post Annual Report)	$45/hr	4 hrs/APR	159	$28,620
GEAR UP staff processing Annual Reports in G5	$45/hr	30 hours		$1,350
Preparing and issuing notifications of Annual Report to grantees and certifying/ authorizing representatives	$45/hr	20 hours		$900
Totals				$63,090

15. 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		1,590	40
Total Responses			4
Total Costs (if applicable)

The APR financial management section has been revised to add new questions about the GEAR UP scholarship component. In addition, a few other questions were revised to clarify and refine information collection in other questions. These changes are estimated to add 10 additional hours per report, for a total increase of 1,590 hours across all grantees.

The annual number of responses and annual burden hours have also been updated to reflect an increase in the number of GEAR UP grantees, resulting in 4 additional responses and 40 additional hours.

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 U.S. Department of Education does not plan to publish any information from this collection.

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 U.S. Department of Education will display the expiration date for the OMB approval for this data collection.

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

No exceptions are being requested for this information collection.

1 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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