SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION
Perkins V State Plan (OMB Control Number 1830-0029)
Justification
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information, or you may provide a valid URL link or paste the applicable section. Please limit pasted text to no longer than 3 pages. 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, make note of the sections or changed sections, if applicable.
This is a request to revise the information collection used by the U.S. Department of Education (Department) to gather State plans from eligible agencies under the Carl D. Perkins Career and Technical Education Act of 2006 (Perkins V) (20 U.S.C. 2301 et seq.) (State Plan Guide or Guide). These revisions would: specify the numerators and denominators for the core indicators of performance.
State plans consist of narrative information, budgets, and performance levels pursuant to Perkins V (in particular, sections 113 and 122), applicable Federal regulations pursuant to the Uniform Guidance (2 CFR 200), and Education Department General Administrative Regulations (34 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, and the outlying areas of the United States Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Marianas Islands, and the Republic of Palau.
A central part of Perkins V is an accountability system that measures and holds States and subrecipients responsible for the outcomes of CTE concentrators using “core indicators of performance” that are described in section 113 of the statute. Each State establishes annual State determined performance levels (SDPLs) that it sets out in its State plan and then agrees upon local levels of performance with subrecipients. Following Perkins reauthorization, when the Department first solicited new State plans in 2019 with this information collection request, it neither specified numerators and denominators for the core indicators nor asked States to specify them in their State plans, with the exception of the secondary program quality indicators. The Department instead retrospectively collected the numerators and denominators used by the States in the Consolidated Annual Report (CAR) information collection request (ICR) (OMB number 1830-0569) to report their actual levels of performance, financial data, and other information about their performance and uses of grant funds.
After closely reviewing the numerators and denominators used by States to measure performance, the Department is now proposing revisions to the State Plan Guide and CAR that describe the numerators and denominators for each of the statutorily required core indicators in both the State Plan Guide ICR and CAR ICR. Because the prior information collections did not specify numerators and denominators that all States must use when reporting, it is not clear that States are including all applicable students required under the law when reporting certain performance indicators. In other cases, State numerator and denominator descriptions previously provided by States are unclear, making it difficult for the Department to determine whether States are measuring what the law requires. Specific to the State Plan ICR, these numerators and denominators would provide clarity to States in determining their annual performance levels by clarifying exactly what performance data the Department would collect for the numerator and denominators in the CAR ICR.
States continue to be solely responsible for establishment of their SDPLs and nothing in this proposed ICR impacts States' ability to set their SDPLs at the numerical values of their choice. We are describing the data to be collected in the numerators and denominators for States to advance several goals: (1) ensure that States measure the indicators in a manner that is consistent with the statute; (2) reduce the collection of potentially duplicative information consistent with section 113(b)(3)(C)(iii) of the law; (3) promote the collection of more accurate and complete data on the post-program outcomes of CTE concentrators by giving States more time to report these data; and (4) improve the consistency of the data collected from States to facilitate the “aggregate analysis” of performance and State-by-State comparisons that sections 113(b)(3)(C)(iv) and 114(a)(1)) of the law, respectively, directs the Department to produce. In addition these data specifications would improve the ability of States to meet the requirements of section 113(b)(3)(A)(i)(III)(dd) of Perkins V, which directs States, in establishing their State-determined performance levels, to “take into account how the levels of performance involved compare with the State levels of performance established for other States, considering factors including the characteristics of actual (as opposed to anticipated) CTE concentrators when the CTE concentrators entered the program, and the services or instruction to be provided.”
Performance Indicator Specifications
For each indicator of performance, the Department proposes to provide States with data specifications for the numerator and denominator as follows.
Graduation Rate ( 1S1 and 1S2)
Section 113(b) (2)(A)(i)(I) of Perkins V identifies as a core indicator of performance the percentage of CTE concentrators who graduate high school, as measured by the four-year adjusted cohort graduation rate (defined in section 8101 of the Elementary and Secondary Education Act of 1965 (ESEA)). We are proposing to specify the data to be included in the numerators and denominators for the four-year graduation rate indicator to ensure consistency with the statutory description of the indicator. The proposed specification includes key provisions of the statutory definition of “four-year adjusted cohort graduation rate” from ESEA section 8101(25), as well as by cross-referencing the definition of “regular high school diploma” from ESEA section 8101(43), a term used in the definition of “four-year adjusted cohort graduation rate.” The specifications would make clear that the numerator and denominator are the numbers of secondary CTE concentrators who, in the reporting year, were included in the numerator and the denominator, respectively, used by the State to calculate the four-year adjusted cohort rate under ESEA. Based on the information States provided with their 2023-24 performance data, it appears that one State is including in the numerator CTE concentrators who were awarded credentials that are not consistent with the ESEA definition of “regular high school diploma.”
Section 113(b)(2)(A)(i)(II) of Perkins V identifies as a core indicator of performance the percentage of CTE concentrators who graduate high school, as measured by the extended-year adjusted cohort graduation rate (defined in ESEA section 8101). Use of this indicator by States is optional. As with the four-year graduation rate indicator, we are proposing to specify the numerator and denominator by directly incorporating key provisions of the definition of “extended-year graduation rate” from ESEA section 8101(23) that is referenced in the statutory description of this indicator. One State using this indicator appears to be including in the numerator CTE concentrators who were awarded credentials that are not consistent with the ESEA definition of “regular high school diploma.”
Academic Proficiency (2S1, 2S2, and 2S3).
Section 113(b)(2)(A)(ii) of Perkins V identifies as a core indicator of performance CTE concentrator proficiency in the challenging State academic standards adopted by the State under ESEA section 1111(b)(1) , as measured by the academic assessments described in ESEA section 1111(b)(2) of such Act. These are assessments in reading/language arts (2S1), mathematics (2S2), and science (2S3).
We are proposing to specify the data to be included in the numerators and denominators for the academic proficiency indicator to ensure consistency with the statutory description of the indicator. These data specifications would:
Include all CTE concentrators in the numerator and denominator, not only those who graduated. Based on their performance reports for the 2022-23 reporting year, seven States appear to be reporting only on CTE concentrators who graduated from high school, excluding from their calculation those CTE concentrators who exited secondary school without graduating. The statute requires measurement of “CTE concentrator proficiency” and does not limit the indicator to high school graduates. The data specification we are proposing would include all CTE concentrators who exited secondary education in the reporting year.
Specify that the numerator and denominator must include the assessment scores of all CTE concentrators who took the assessments. During the 2021-22 reporting year, at least seven States may have excluded from their measurement of the indicator the scores of CTE concentrators who did not attend the same school within a local educational agency (LEA) for at least half of a school year. We surmise this because their numerators refer to using the same student proficiency data used to calculate the academic achievement indicator in the State system of annual meaningful differentiation for schools authorized by ESEA Title I, Part A. Under the ESEA, the State must exclude from the academic achievement indicator the scores of any student who has not attended the same school within a LEA for at least half of a school year.1 However, the Perkins V statute does not provide for the exclusion of the scores of students who attended school for only part of the year. The data specifications we propose would use the ESEA scores that were used to calculate proficiency in reading/language arts, mathematics, and science for State and local report cards under ESEA, Title I, Part A. These are the scores of all students who took the assessment, including the scores of students with partial attendance, which must be reported under ESEA (though not used for the ESEA academic achievement indicator).2 Therefore, this specification would ensure that the assessment scores of all CTE concentrators on the ESEA assessments are counted in measuring academic proficiency for Perkins V.
Specify that the data in the numerator only include CTE concentrators who achieved proficiency or higher. For high schools only, States may choose to include in the ESEA Title I, Part A academic achievement indicator the scores of students who demonstrate growth in their performance on the reading/language arts and mathematics assessments, in addition to students who demonstrated proficiency.3 For the Perkins 2022-23 reporting year, based on the performance reports they submitted, two States may have counted the scores of CTE concentrators who demonstrated growth as if they achieved proficiency. Section 113(b)(2)(A)(ii) of Perkins V provides that the core indicator measures “CTE concentrator proficiency” exclusively. For this reason, the Department is specifying that the data sources for the academic proficiency indicator are the scores of CTE concentrators that are used to report on student performance in the State and LEA report cards under ESEA Title I, Part A.
Provide for the reporting of a CTE concentrator’s academic proficiency once only, in the reporting year they exit secondary education. Section 113(b)(3)(C)(iii) of Perkins V directs the Secretary to “ensure that each eligible agency does not report duplicative information” under section 113. The specifications we are proposing for the numerators and denominators of the academic proficiency indicator would prevent the collection of duplicative information by including only the scores of CTE concentrators who exited secondary education in the reporting year (i.e., use an exit cohort). For the 2022-23 reporting year, 22 states reported using an “active” cohort of students, which means that these States reported on all students who were presently enrolled across each grade level and who met the definition of CTE concentrator in the reporting year. This includes all students who met the definition of CTE concentrator in the reporting year, which, depending on the State, could include students who are sophomores, juniors, and seniors. For example, if a State assessment occurs in 10th grade and a student becomes a CTE concentrator in that same year, these States report on the academic proficiency of that student following the student’s enrollment in each of 10th, 11th, and 12th grades. As a result, the State would be reporting on the academic proficiency of the same CTE concentrator in three consecutive years. Another 26 States reported using an “exit” cohort, meaning that they reported only once on the academic proficiency of CTE concentrators, after they exited secondary school. Additionally, it is unclear whether five States used an “active” or “exit” cohort. We are proposing to collect data on CTE concentrators who exited secondary education in the reporting year for this indicator because Perkins V requires alignment of both the one-time ESEA assessment measuring proficiency and the identification of CTE concentrators which may not be available until the student exits the program. Reporting one-time assessment results for individual students in multiple years, i.e., the use of an “active” cohort, may result in duplicative reporting that section 113(b)(3)(C)(iii) directs the Department to prevent. This change would also bring Perkins into alignment with ESEA approach to reporting proficiency data (i.e. reporting student proficiency data only one time during secondary school). We believe that reporting data on an exiting cohort would provide a more transparent picture of CTE concentrator academic proficiency for policymakers, taxpayers, and parents.
Secondary Post-Program Placement (3S1).
Section 113(b)(A)(iii) of Perkins V identifies as a core indicator of performance the percentage of secondary CTE concentrators who, in the second quarter after exiting from secondary education, are in postsecondary education or advanced training, military service or a service program that receives assistance under Title I of the National and Community Service Act of 1990 (42 U.S.C. 12511 et seq.), are volunteers as described in section 5(a) of the Peace Corps Act (22 U.S.C. 2504(a)), or are employed.
The ICR numerator and denominator specifications would clarify that States must include all CTE concentrators in the numerator and denominator who exited secondary education, not only those who graduated. For the 2022-23 reporting year, it appears that at least 18 States may have reported only on the post-program outcomes of CTE concentrators who graduated from high school, excluding CTE concentrators who exited from secondary education without graduating. The statute refers to only “CTE concentrators who, in the second quarter after exiting from secondary education” and does not limit the measure to CTE concentrators who graduated from high school. Under the proposed revisions, States must include all CTE concentrators who exited secondary education in the numerator and denominator.
The Department is also including specifications that address the timing of the program year that should be included in the numerator and denominator for the post-program secondary indicator. The justification for this change is discussed more fully in the postsecondary indicator, which contains a similarly constructed revision.
Secondary and Postsecondary CTE Concentrators in Non-traditional Fields (4S1 and 3P1).
Sections 113(b)(2)(A)(v) and 113(b)(2)(B)(iii) of Perkins V establishes as core indicators of performance the percentage of secondary and postsecondary CTE concentrators, respectively, in CTE programs and programs of study that lead to non-traditional fields. Section 3(33) of Perkins V defines the term “non-traditional fields” as “occupations or fields of work, such as careers in computer science, technology, and other current and emerging high skill occupations, for which individuals from one gender comprise less than 25 percent of the individuals employed in each such occupation or field of work.” The Department is proposing specifying numerators and denominators for both the secondary and postsecondary indicators in a similar fashion and describes the justification for both as follows.
During the 2022-23 reporting year, most States measured these two core indicators in the same way, with the same numerators and denominators. The small number of States that established different definitions preclude the aggregation of the data to measure national progress in reducing occupational segregation by gender and to compare performance on these indicators across States. We are proposing specifications for these numerators and denominators that best reflect the statute and that are consistent with the manner in which the majority of States now report the data:
Specify that the denominator is the number of CTE concentrators who are concentrating their studies in a CTE program or program of study that leads to a non-traditional field, not all CTE concentrators. During the 2022-23 reporting year, all States used the same data source for the numerator for 4S1: the number of CTE concentrators in programs designated as non-traditional for males or females who are the gender that is non-traditional for the program, such as, for example, males in nursing and females in automotive technology. All but 8 States identified as the denominator for 4S1 the total number of CTE concentrators in programs designated as non-traditional for males or females. The remaining 8 States identified as the denominator for 4S1 the total number of CTE concentrators in all programs. There was less variation in how States measured 3P1; only 4 States identified as the denominator for 3P1 all CTE concentrators. Four of the States that identified the total number of CTE concentrators as the denominator for 4S1 did not do this for 3P1; like most other States, they instead identified as the denominator for 3P1 the total number of CTE concentrators in programs designated as non-traditional for males or females. We propose to collect the number of CTE concentrators who are in CTE programs and programs of study that lead to non-traditional fields as the denominator (i.e., the approach taken by most States) for 4S1 and 3P1 because it results in the collection of data that measures the extent to which segregation by gender in CTE programs and programs of study that lead to non-traditional fields is being reduced, consistent with the Perkins statute. If States continued using the alternative measurement approach, the total number of CTE concentrators as the denominator, this indicator would be redundant. The ICR already collects this information on the CTE Concentrator Enrollment Form, which requires States to disaggregate the number of CTE concentrators who are enrolled in CTE programs or programs of study that are non-traditional for their gender.
Specify that the students who are CTE concentrators and are concentrating their studies in a CTE program or program of study that leads to non-traditional fields for their gender are included in the numerator and denominator. During the 2022-23 reporting year, for 4S1, most States measured the percentage of students who were CTE concentrators in CTE programs or programs of study that are non-traditional for their gender. Four States included CTE students in the numerator for 4S1 if they took or passed only one course that was in a CTE program or program of study that was non-traditional for their gender; for those States, students need not, in other words, be concentrating their studies in a CTE program in a non-traditional field in order to be included in the numerator. For 3P1, eight States appear to have included CTE concentrators in the numerator if they were enrolled in a program that was non-traditional for their gender but did not concentrate their studies in that program. We propose to collect information for the numerators for 4S1 and 3P1 that is limited to students who are concentrating their studies in a CTE program or program of study that leads to a non-traditional field because we believe this reflects the statutory intent of the indicator. Perkins IV, the predecessor statute, required States to measure and negotiate performance levels for “Student participation in and completion of career and technical education programs that lead to non-traditional fields” at the secondary level and “student participation in, and completion of, career and technical education programs that lead to employment in non-traditional fields” at the postsecondary level. In reauthorizing the law in 2018, Congress removed the references to “student participation” and “completion,” replacing them with “the percentage of CTE concentrators in CTE programs and programs of study that lead to non-traditional fields” at both the secondary and postsecondary levels. We think Congress purposively changed the reference from “student participation” to “CTE concentrators” to focus this indicator on students who concentrate their studies (i.e., are CTE concentrators) in CTE programs and programs of study that lead to non-traditional fields and request that States report accordingly.
Specify that the numerator is the number of CTE concentrators from the minority gender in CTE programs or programs of study that lead to non-traditional fields. For 3P1, three States identified as the numerator all CTE concentrators in CTE programs and programs of study that lead to non-traditional fields, not only those from the minority gender. For 4S1, even though it is largely the same as 3P1, with the former applicable to secondary CTE and the latter applicable to postsecondary CTE, all States identified as the numerator students from the minority gender who were concentrating their studies in a CTE program or program of study that leads to non-traditional fields. We proposed to specify the numerators for 4S1 and 3P1 are CTE concentrators from the minority gender in CTE programs or programs of study that lead to non-traditional fields because this reflects the statutory intent of the indicator.
Specify that CTE concentrators from the minority gender in CTE programs or programs of study that lead to non-traditional fields are included in the numerator in each reporting year in which they meet these criteria. This means that CTE concentrators from the minority gender in a CTE program or program of study that leads to a non-traditional field would be reported in multiple years, and not only upon their exit from secondary education and completion of postsecondary education. For 4S1, three States reported CTE concentrators from the minority gender in CTE programs or programs of study that lead to non-traditional fields only when they exited secondary education; for 3P1, four States reported these students upon their completion of a program. We propose to use an “active cohort” for these indicators, collecting data on students who meet the criteria in each year they meet them, because the overwhelming majority of States now report on these indicators as an ”active cohort.” We think this is an important consideration given the burden that would be associated with making this change. Unlike the academic proficiency indicators, which are intended to measure CTE concentrator proficiency on one-time assessments, the non-traditional field indicator captures students’ annual status as studying in a non-traditional field; a student’s status may change in different years in which they are a CTE concentrator. For the academic proficiency indicators, on the other hand, a plurality of States are already using an “exit cohort.”
Secondary Program Quality (5S1, 5S2, 5S3)
Section 113(b)(2)(A)(iv) of Perkins V gives States a choice among three secondary program quality indicators, which include the percentage of CTE concentrators graduating from high school having: (1) attained a recognized postsecondary credential(5S1); (2) attained postsecondary credits in the relevant CTE program or program of study earned through a dual or concurrent enrollment program or another credit transfer agreement (5S2); or (3) participated in work-based learning (5S3).
For 5S2 in particular, we are proposing to specify the numerator of the postsecondary credits attainment indicator. States would include in the numerator only those CTE concentrator high school graduates who earned postsecondary credits “in the relevant career and technical education program or program of study" as specified in section 113(b)(2)(A)(iv)(I)(bb) of Perkins V. Five of the 12 States using this indicator during the 2022-23 reporting year did not specify in their numerator that the postsecondary credits were earned “in the relevant career and technical education program or program of study” as required by the statute, which we note would include both academic and technical coursework as part of the program. The proposed data specifications for 5S1, attained recognized postsecondary credential, and 5S1, participated in work-based learning, are based on the statute and appear to be consistent with how States have been measuring these indicators.
Post-program Placement (1P1 and 3S1)
Perkins V establishes two core indicators that measure the outcomes of CTE concentrators after exit or completion. In addition to the post-program placement indicator for secondary CTE concentrators described previously, section 113(b)(2)(B)(i) of Perkins V identifies as a core indicator of performance the percentage of postsecondary CTE concentrators who, during the second quarter after program completion, remain enrolled in postsecondary education, are in advanced training, military service, or a service program that receives assistance under title I of the National and Community Service Act of 1990 (42 U.S.C. 12511 et seq.), are volunteers as described in section 5(a) of the Peace Corps Act (22 U.S.C. 2504(a)), or are placed or retained in employment.
The numerator and denominator specifications we are proposing for these two indicators would specify that the reporting period is the preceding reporting year.
Using the preceding reporting year as the reporting period would give States 16 months (i.e., an additional program year) to gather data on the post-program outcomes of CTE concentrators. This change would improve the completeness and accuracy of these data. Most States take four months after the end of the reporting year (i.e., from October 1 until January 31 when the CAR performance data is generally due to the Department) to determine the employment and educational outcomes of secondary CTE concentrators who exited secondary education and postsecondary CTE concentrators who completed a CTE program or program of study in June of the reporting year. This does not provide sufficient time for States to access administrative data (e.g., unemployment insurance wage records), like they do with programs authorized by the Workforce Innovation and Opportunity Act. While State unemployment insurance wage records do not include data on workers who are self-employed, employed as independent contractors, or employed by the Federal government,4 they are an important data source on employment5 that States should be able to use to identify the employment status of CTE concentrators after they exit secondary education or complete a postsecondary program. The results of student surveys administered by schools, LEAs, and institutions of higher education may not be accurate if the surveys have a low response rate.6 Using unemployment insurance wage records also may be less expensive than administering surveys.7 For CTE concentrators who exit high school or complete a postsecondary program in June of the reporting year, the end of the second quarter after exit or completion is December 31. Most States collect unemployment insurance wage records on a quarterly basis, and there is typically a lag after the end of a quarter before it is available for matching.8 For this reason, we are proposing to specify that the numerator and denominator for the secondary and postsecondary post-program indicators is CTE concentrators who exited or completed during the preceding program year, giving States 16 months to collect these data.
Attainment of a Recognized Postsecondary Credential by Postsecondary CTE Concentrators (2P1)
Section 113(b)(2)(B)(ii) of Perkins V establishes as a core indicator of performance the percentage of postsecondary CTE concentrators who receive a recognized postsecondary credential during participation in or within 1 year of program completion.
For the attained recognized postsecondary credential indicator, we describe the numerator as “the number of CTE concentrators at the postsecondary level who received a recognized postsecondary credential in the reporting year or who were enrolled in the previous reporting year and earned their credential in the reporting year” and the denominator as “the number of CTE concentrators at the postsecondary level who were enrolled in the reporting year or who were enrolled in the previous reporting year and earned a recognized postsecondary credential in the reporting year.” This specification would assure alignment with the law and improve the consistency of State data.
While States used similar numerators for this indicator that are comparable to our specification, there is great variation in their denominators. In their 2023-24 performance reports, States used at least eight different variations of the denominator, with some measuring attainment of CTE concentrators who exited during the prior reporting year, some measuring attainment by CTE concentrators who exited during the reporting year, others measuring attainment by CTE concentrators who completed a program during the prior year, and so forth. Consequently, data for this indicator cannot responsibly be aggregated nationally or used to make State-by-State comparisons as is required in sections 113(b)(3)(C)(iv) and 114(a)(1) of Perkins. We believe the numerator and denominator we propose best reflect the statutory description of the indicator.
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.
Pursuant to section 122(f), the Department uses the information contained in each eligible agency’s State plan and annual revisions to determine whether the eligible agency has met the requirements of the Act, including submitting State-determined levels of performance that meet the criteria established in section 113(b)(3) and section 113(b)(3)(A)(i)(III). The Department also uses the information to determine areas in need of technical assistance in States, and to provide information on State’s Perkins V initiatives, funding, and performance levels to Congress, interested stakeholders, and the public. States also use the data to measure and improve the outcomes of CTE programs and programs of study.
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 requires eligible agencies to submit State plans and annual revisions electronically via the Perkins V State Plan Portal at https://perkins.ed.gov/pims.
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.
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.
The collection does not impact small businesses or other small entities.
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.
Pursuant to section 122(a)(1) of Perkins V, each eligible agency must submit a State plan or annual revisions for any fiscal year in which they seek assistance under the Act.
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.
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. 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 consulted eight different stakeholder groups and four different State CTE directors when drafting this update to understand both the usefulness of collecting and the availability of these data. The Department published a 60-day notice in the Federal Register on September 11, 2024. We received 53 sets of comments on the Perkins V State Plan Guide that were submitted through Regulations.gov. We also received comments from State agency officials during briefings about the revisions to the two ICRs and in correspondence from members of Congress. In the attached document, we address all of the comments we received on the Perkins V State Plan Guide and describe the changes we are making to the Perkins V State Plan Guide in response to these comments.
The Department will publish a 30-day notice in the Federal Register and will review and respond to the comments received. Changes will be made when appropriate.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.
There will be no payments or gifts to respondents of this information collection.
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. 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). 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 confidentially of the data.
The Department makes no pledge about the confidentiality of the data provided by respondents of this information collection.
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.
Provide estimates of the hour burden of the collection of information. The statement should:
• 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, and an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. 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 the ROCIS IC Burden Analysis Table. (The table should at minimum include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)
• 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.
To determine the estimated burden hours associated with the Perkins V State plan collection, the Department originally consulted State employees who are responsible for State plan development at nine eligible agencies. The Department later adjusted its first estimated burden hours based on public comments from the 60-day comment period in 2019. To estimate burden for this revision and renewal, we consulted with four State eligible agency officials responsible for State plan development, two professional associations that represent CTE administrators at the State and local levels, and two associations that represent other CTE stakeholders.
We estimate that the burden hours per response averaged across the three years of this information collection request will be 19 hours. Our estimates make the following assumptions:
For 2025, all 54 respondents will submit revisions to their State Determined Performance Levels (SDPLs) and budgets for the forthcoming fiscal year’s State allocation;
For 2026, all 54 respondents will submit revisions to their State Determined Performance Levels (SDPLs) and budgets for the forthcoming fiscal year’s State allocation; and
For 2027, all 54 respondents will submit revisions to their State Determined Performance Levels (SDPLs) and budgets for the forthcoming fiscal year’s State allocation.
The estimates for every year include the time required to review instructions, prepare a budget for the forthcoming fiscal year’s State allocation, participate in training for the information collection tool, and to respond to the information collection.
The estimates for submitting revisions to SDPLs also includes time required to compute any revisions to SDPLs, as well as the time required for public comment and responding to any comments.
Year |
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)
|
2025 |
N/A |
100% |
54 |
54 |
19 |
1,026 |
$72.72 |
$74,611 |
2026 |
N/A |
100% |
54 |
54 |
19 |
1,026 |
$72.72 |
$74,611 |
2027 |
N/A |
100% |
54 |
54 |
19 |
1,026 |
$72.72 |
$74,611 |
Annualized Totals |
N/A |
100% |
54 |
54 |
19 |
1,026 |
$72.72 |
$74,611 |
We estimate the total cost per hour of the professional staff who will carry out this work to be $72.72 per hour, the mean hourly compensation cost for State and local government workers who were in management, professional, and related occupations in March 2024.9 The total annualized cost to respondents of the hour burdens for this collection is estimated to be $74,611, as indicated in the table below. Within that amount the Department has adjusted our estimates to indicate that professional staff would be solely responsible for this submission, without assistance from clerical staff (our previous estimate had assumed that 12 hours of assistance would be provided by clerical staff).
Type of Staff |
Total Estimated Number of Burden Hours |
Estimated Hourly Cost |
Total Costs (Rounded to the Nearest dollar) |
Professional |
1,026 |
$72.72 |
$74,611 |
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: $0
Total Annual Costs (O&M): $0
Total Annualized Costs Requested: $0
The total for the capital and start-up cost components for this information collection is zero. The information collection will not require the purchase of any capital equipment nor create any start-up costs. Computers and software used to complete this information collection are part of the respondents’ customary and usual business or private practices, and therefore is not included in this estimate. The total operation and maintenance and purchase of service components for this collection is zero. The information collection will not create costs associated with generating, maintaining, and disclosing or providing the information that is not already identified in Item 12 of this supporting statement.
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.
As indicated in the table below, the estimated annualized cost to the Federal government is $16,480. This includes salaries of five program staff who develop the State plan guide, revise the State plan submission portal, provide annual training technical assistance to eligible agencies regarding the submission of information, and review and approve State plans, revisions, and annual budgets.
Number of Employees |
Employee Grade |
Estimated Average Number of Hours Per Employee |
Total Average Number of Estimated Hours |
Estimated Average Hourly Cost |
Total Annualized Costs |
(Rounded to the Nearest .10) |
|||||
2 |
GS-13 |
46 |
93 |
$64.06 |
$5,957.60 |
3 |
GS-14 |
46 |
139 |
$75.70 |
$10,522.30 |
TOTAL |
$16,479.90 |
||||
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 |
Annual Burden |
|
-594 |
|
Annual Responses |
|
|
|
The expiring authorization for this information collection had a burden of 1,620 hours. The new burden is 1,026 hours. These new proposed revisions to the State Plan Guide would decrease burden due to a change in the agency estimate. The Department now estimates that no new additional States will submit new State plans and that all 54 respondents will only submit revisions to their State Determined Performance Levels (SDPLs) and budgets for the forthcoming fiscal year’s State allocation in each year (i.e., 2025, 2026, and 2027).
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.
Timeline |
Actions |
January |
Department issues program memorandum with due dates and reminders regarding State plan submissions |
No later than March10 |
Department issues program memorandum with estimated allocations for each State for the upcoming fiscal year |
Spring Date to Be Determined11 |
Eligible agencies submit State plans or annual revisions |
June 30 |
Department approves State plans or annual revisions that meet the requirements of the statute |
July 1 |
Department issues 1st installment of State’s Perkins V grant awards for the upcoming fiscal year |
October 1 |
Department issues supplemental and final installment of State’s Perkins V grant awards for the upcoming fiscal year |
State plans are integrated with other State information that now appears on the Department’s website at https://cte.ed.gov/profiles/national-summary.
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.
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.
Appendix
Summary Highlights of the Proposed Data Specifications for the Perkins V Core Indicators of Performance
Indicator |
Statute |
Proposed Data Specifications
|
Notes |
Secondary Education
|
|||
1S1: Four-Year Graduation Rate |
“The percentage of CTE concentrators who graduate high school, as measured by—(I) the four-year adjusted cohort graduation rate (defined in section 8101 of the Elementary and Secondary Education Act of 1965)” |
Numerator: The number of CTE concentrators at the secondary level who, in the reporting year, are included in the numerator for the four-year adjusted cohort graduation rate under ESEA section 8101(25)(A)(ii) (i.e., the number of CTE concentrators at the secondary level who graduated from high school with a regular high school diploma as defined in ESEA section 8101(43) at the conclusion of the fourth year of high school or the summer session immediately following the fourth year of high school; plus, if the State has adopted an alternate diploma, all CTE concentrators with the most significant cognitive disabilities who were assessed using an alternate assessment aligned with alternate academic achievement standards under ESEA section 1111(b)(2)(D) and who graduated with a State-defined alternate diploma that is standards-based, aligned with the State requirements for the regular high school diploma, and obtained within the time period for which the State ensures the availability of a free appropriate public education under section 612(a)(1) of the Individuals with Disabilities Education Act, in the reporting year).
Denominator: The number of CTE concentrators at the secondary level who, in the reporting year, were included in the four-year adjusted cohort (i.e., denominator) used to calculate the four-year adjusted cohort graduation rate (as defined in ESEA section 8101(25)). |
|
1S2: Extended-Year Graduation Rate (State Option) |
“The percentage of CTE concentrators who graduate high school, as measured by—(II) at the State’s discretion, the extended-year adjusted cohort graduation rate defined in such section 8101.” |
Numerator: The number of CTE concentrators at the secondary level who, in the reporting year, are included in the numerator for the extended-year adjusted cohort graduation rate under ESEA section 8101(23)(A)(ii) (i.e., the number of CTE concentrators at the secondary level who earned a regular high school diploma as defined in ESEA section 8101(43) before, during, or at the conclusion of one or more additional years beyond the fourth year of high school, or a summer session immediately following the additional year of high school; and all students with the most significant cognitive disabilities in the cohort assessed using the alternate assessment aligned to alternate academic achievement standards under ESEA section 1111(b)(2)(D) and awarded a State-defined alternate diploma that is standards-based; aligned with the State requirements for the regular high school diploma; and obtained within the time period for which the State ensures the availability of a free appropriate public education under section 612(a)(1) of the Individuals with Disabilities Education Act (20 U.S.C. 1412(a)(1) in the reporting year).
Denominator: The number of CTE concentrators at the secondary level who, in the reporting year, were included in the adjusted cohort (i.e., denominator) used to calculate the extended-year adjusted cohort graduation rate (as defined in section 8101(23) of ESEA). |
|
2S1: Academic Proficiency in Reading/Language Arts 2S2: Academic Proficiency in Mathematics 2S3: Academic Proficiency in Science |
“CTE concentrator proficiency in the challenging State academic standards adopted by the State under section 1111(b)(1) of the Elementary and Secondary Education Act of 1965, as measured by the academic assessments described in section 1111(b)(2) of such Act” |
Numerator: The number of CTE concentrators who achieved proficiency or higher in reading/language arts in the challenging State academic standards adopted by the State under ESEA section 1111(b)(1), as measured by the academic assessments described in ESEA section 1111(b)(2), whose scores were reported by the State in accordance with ESEA section 1111(h)(1)(C)(ii) for any year in which the student was enrolled in the school, and who, in the reporting year, exited secondary education.
Denominator: The number of CTE concentrators who took the ESEA assessment in reading/language arts whose scores were reported by the State in accordance with ESEA section 1111(h)(1)(C)(ii) for any year in which the student was enrolled in school, and who, in the reporting year, exited secondary education.
Numerator: The number of CTE concentrators who achieved proficiency or higher in mathematics in the challenging State academic standards adopted by the State under ESEA section 1111(b)(1), as measured by the academic assessments described in ESEA section 1111(b)(2), whose scores were reported by the State in accordance with ESEA section 1111(h)(1)(C)(ii) for any year in which the student was enrolled in the school, and who, in the reporting year, exited secondary education.
Denominator: The number of CTE concentrators who took the ESEA assessment in mathematics whose scores were reported by the State in accordance with ESEA section 1111(h)(1)(C)(ii) for any year in which the student was enrolled in school, and who, in the reporting year, exited secondary education.
Numerator: The number of CTE concentrators who achieved proficiency or higher in science in the challenging State academic standards adopted by the State under ESEA section 1111(b)(1) , as measured by the academic assessments described in ESEA section 1111(b)(2), whose scores were reported by the State in accordance with ESEA section 1111(h)(1)(C)(ii) for any year in which the student was enrolled in the school, and who, in the reporting year, exited secondary education.
Denominator: The number of CTE concentrators who took the ESEA assessment in science whose scores were reported by the State in accordance with ESEA section 1111(h)(1)(C)(ii) for any year in which the student was enrolled in school, and who, in the reporting year, exited secondary education.
|
|
3S1: Post-Program Placement
|
“The percentage of CTE concentrators who, in the second quarter after exiting from secondary education, are in postsecondary education or advanced training, military service or a service program that receives assistance under title I of the National and Community Service Act of 1990 (42 U.S.C. 12511 et seq.), are volunteers as described in section 5(a) of the Peace Corps Act (22 U.S.C. 2504(a)) or are employed.” |
Numerator: The number of students who were CTE concentrators and exited secondary education during the preceding reporting year, who, in the second quarter after exiting from secondary education, were enrolled in postsecondary education, advanced training, military service, or a service program that receives assistance under title I of the National and Community Service Act of 1990 (42 U.S.C 12511 et seq.), or were volunteers as described in section 5(a) of Peace Corps Act (22 U.S.C. 2504(a)), or were employed.
Denominator: The number of CTE concentrators who exited secondary education in the preceding reporting year.
|
|
4S1: Non-traditional Program Concentration
|
“The percentage of CTE concentrators in career and technical education programs and programs of study that lead to non-traditional fields.” |
Numerator: The number of CTE concentrators in secondary CTE programs and programs of study that lead to non-traditional fields who are a gender that comprises less than 25 percent of the individuals employed in the occupation or field of work for which the CTE program prepares students.
Denominator: The number of CTE concentrators in secondary CTE programs and programs of study that lead to non-traditional fields. |
|
5S1: Program Quality – Attained Recognized Postsecondary Credential
|
“The percentage of CTE concentrators graduating from high school having attained a recognized postsecondary credential” |
Numerator: The number of CTE concentrators who graduated from high school in the reporting year who have attained a recognized postsecondary credential.
Denominator: The number of CTE concentrators who graduated from high school in the reporting year. |
|
5S2: Program Quality – Attained Postsecondary Credits
|
“The percentage of CTE concentrators graduating from high school having attained postsecondary credits in the relevant career and technical education program or program of study earned through a dual or concurrent enrollment program or another credit transfer agreement.”
|
Numerator: The number of CTE concentrators who graduated from high school in the reporting year having attained through dual or concurrent enrollment or another credit transfer agreement postsecondary credits in the relevant career and technical education program or program of study in which each student concentrated their studies.
Denominator: The number of CTE concentrators who graduated from high school in the reporting year.
|
|
5S3: Program Quality – Participated in Work-Based Learning
|
“The percentage of CTE concentrators graduating from high school having participated in work-based learning.” |
Numerator: The number of CTE concentrators graduating from high school in the reporting year having participated in work-based learning.
Denominator: The number of CTE concentrators who graduated from high school in the reporting year. |
|
Postsecondary Level
|
|||
1P1: Postsecondary Placement |
“The percentage of CTE concentrators who, during the second quarter after program completion, remain enrolled in postsecondary education, are in advanced training, military service, or a service program that receives assistance under title I of the National and Community Service Act of 1990 (42 U.S.C. 12511 et seq.), are volunteers as described in section 5(a) of the Peace Corps Act (22 U.S.C. 2504(a)), or are placed or retained in employment.”
|
Numerator: The number of students who were CTE concentrators at the postsecondary level during the preceding reporting year who, during the second quarter after program completion, remained enrolled in postsecondary education, were in advanced training, military service, or a service program that receives assistance under title I of the National and Community Service Act of 1990 (42 U.S.C. 12511 et seq.), were volunteers as described in section 5(a) of the Peace Corps Act (22 U.S.C. 2504(a)), or were placed or retained in employment.
Denominator: The number of students who were CTE concentrators at the postsecondary level who completed a CTE program or program of study during the preceding reporting year. |
|
2P1: Earned Recognized Postsecondary Credential |
“The percentage of CTE concentrators who receive a recognized postsecondary credential during participation in or within 1 year of program completion.” |
Numerator: The number of CTE concentrators at the postsecondary level who received a recognized postsecondary credential during participation in the reporting year or within one year of program completion.
Denominator: The number of CTE concentrators at the postsecondary level enrolled in the reporting year or who completed a CTE program during the previous reporting year. |
|
3P1: Non-traditional Program Concentration |
“The percentage of CTE concentrators in career and technical education programs and programs of study that lead to non-traditional fields.” |
Numerator: The number of CTE concentrators in postsecondary CTE programs and programs of study that lead to non-traditional fields who are a gender that comprises less than 25 percent of the individuals employed in the occupation or field of work for which the CTE program prepares students.
Denominator: The number of CTE concentrators in postsecondary CTE programs and programs of study that lead to non-traditional fields. |
[Same specifications as 4S1: Non-traditional Program Concentration, except that CTE concentrators are at the postsecondary level]
|
1 ESEA, §1111(c)(4)(F)(i)(I).
2 ESEA, §1111(c)(4)(F)(i)(II).
3 ESEA, §1111(c)(4)(B)(i)(I).
4 Czajka, J.L., et al. (2018) Data on Earnings: A Review of Resources for Research, Mathematica Policy Research. Retrieved from: https://www.dol.gov/sites/dolgov/files/OASP/legacy/files/Data-on-Earnings-Report.pdf.
5 Congdon, W.L. and Katz, B. (2023), Job Quality and Wage Records The Potential Role of Administrative Wage Data for Understanding Job Quality, the Urban Institute. Retrieved from: https://www.urban.org/sites/default/files/2023-05/Job%20Quality%20and%20Wage%20Records.pdf.
6 Office of Information and Regulatory Affairs, Office of Management and Budget. 2016. Questions and Answers When Designing Surveys for Information Collections. Retrieved from: https://obamawhitehouse.archives.gov/sites/default/files/omb/inforeg/pmc_survey_guidance_2006.pdf. See also Czajka, J.L., et al., op. cit.
7 Czajka, J.L., et al., op. cit.
8 U.S. Department of Education, Office of Career, Technical, and Adult Education (2019), Demonstrating Success: A Technical Assistance Guide for Collecting Postexit Indicators. Retrieved from: https://nrsweb.org/sites/default/files/Post-Exit-Guide-508.pdf.
9 Bureau of Labor Statistics, U.S. Department of Labor, Employer Costs for Employee Compensation Historical Listing, National Compensation Survey, retrieved from https://www.bls.gov/web/ecec/ecec-government-dataset.xlsx
10 The Department will publish estimated State allocations no later than March provided that an appropriation for the next fiscal year has been enacted into law by this time.
11 Where practicable, the Department may determine that it does not need the full 120 day period allowable under section 122(f) of Perkins V to review State plans and/or revisions and issue Perkins grant awards on schedule on July 1.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Goetz, Braden |
| File Modified | 0000-00-00 |
| File Created | 2024-12-03 |