Supporting Statement for Paperwork Reduction Act Submission
ESEA Consolidated State Reporting Instrument
March 30, 1998
A. Justification
1. a. Reasons to Promote Consolidated Reporting. Under the various state formula grant programs included in the Elementary and Secondary Education Act (ESEA,) reauthorized as (Title I of the Improving America's Schools Act (IASA)), the Department of Education distributes approximately $10 billion to States and, through them, to local educational agencies and other subgrantees for purposes of improving the educational achievement of the nation's students. In implementing these formula grant programs, the reauthorized ESEA emphasizes the importance of cross-program coordination and integration of the ESEA programs into the education activities supported with state and local funds as keys to improving teaching and learning. Moreover, in 1995, under authority of section 14301 of the ESEA, the Department offered to States the opportunity to receive funding under these programs on the basis of consolidated State plans rather than individual program plans or applications that the individual ESEA program statutes otherwise require. As of February 1998, all but one State (along with the District of Columbia and Puerto Rico) receive funding under most if not all ESEA state formula grant programs on the basis of consolidated plans that focus on improving teaching and learning through cross-program coordination and integration of those programs into activities supported with state and local resources.
However, the reporting that the Department currently has all states provide on uses of these funds, program performance, and program beneficiaries has continued to be required on a program-by-program basis. This individual program reporting has seemed to many -- at the state and federal levels -- to be inconsistent with the focus of the IASA and consolidated plans on aligning the ESEA programs with each other and with state and local education efforts to improve teaching and learning. Indeed, the very fact that the Department has invited States to design and implement their ESEA programs on the basis of consolidated planning, and yet continues to have them report on a program-program basis, sends a confusing and inconsistent message to the public about the importance of bringing the power of federal program funds to bear through cross-program coordination and integration into state and local activities. In this regard, officials in a number of states and the Council of Chief State School Officers (CCSSO) have urged the Department to develop a reporting instrument that would not only eliminate unnecessary reporting, but would combine into a single document all of the reporting elements that would otherwise be asked of them in individual ESEA reporting forms.
The state consolidated performance report is intended as an initial step toward an optimal design to track indicators of program performance. The Department is required to present performance information to the Congress under the Government Performance and Results Act of 1993 and congressional mandates for the national assessment of Title I (Sec. 1501), and evaluation of the federal impact on reform (Sec. 14701) contained in the 1994 reauthorization of the ESEA. The Department submitted a full series of program performance indicator plans, along with its Fiscal Year 1999 annual plan, to Congress for the first time in February 1998. Several of the indicators in the plans rely on the state consolidated performance reports to provide information on student performance, participation, and program implementation.
Reporting is an iterative process; it is expected that reporting will change as the U.S. Department of Education and the states develop their capacities to elicit and use accurate and reliable information for monitoring, reporting, and improvement. The Department is eager to work with individual States, including through the CCSSO, to support efforts to improve the quality, timeliness, and efficiency of information collection and use. Concerns with respondent burden and usefulness will continue to be a paramount concern as we work to provide the best possible performance to our ultimate customers -- students, parents and taxpayers across the country.
b. Programs covered by the consolidated reporting instrument. This single instrument, for use after the 1998-99 school year, would include all needed reporting elements for the following ESEA programs:
Title I, Part A Helping Disadvantaged Children Meet High Standards
Title I, Part C Migrant Education
Title I, Part D Neglected or Delinquent Children
Title II Eisenhower Professional Development
Title III Technology Literacy Challenge Fund
Title VI Innovative Education Program Strategies
In addition, because of the relationship of these programs and the ESEA consolidated plans to a State's own education reform plan, this consolidated reporting instrument also includes all necessary data elements for:
Goals 2000: Educate America Act
[NOTE: States also may receive funds under both Title I, Part B (Even Start) and Title IV, subpart 1 (Safe and Drug-Free Schools and Communities) on the basis of consolidated state plans. The consolidated reporting instrument would not bring in either program. Information needed for the Even Start program would continue to be gathered through a program evaluation. Data collection under Title IV, which by law is optional for the 1998-99 school year, is too interrelated to data collections needed as part of the Administration's overall drug and violence prevention strategies to be appropriate for inclusion in the consolidated instrument.]
c. The need for this collection of information. In response to these various factors, the Department would have State education agencies (SEAs) submit a consolidated reporting form rather than individual program specific reporting forms. (While all States would furnish programmatic information requested in the Tables I and II and Charts A and B, the one State - Utah - that elected not to receive program funding on the basis of a consolidated State plan would not need to respond to the "General Questions" at the beginning of the report form) This single instrument is needed so as to --
(1) allow the public to see at one time and in one place all reporting elements under these programs;
(2) promote unified and simplified data collection by both SEAs and their subgrantees;
(3) permit the public, as well as local, state and federal officials, to examine how data collected for the various ESEA programs and Goals 2000 fit together; and
(4) provide information to the Department (and to the public) on a critical but missing piece of their implementation of ESEA programs -- how States are implementing the goals, strategies, uses of resources and other elements they described in their approved consolidated plans.
The consolidated reporting instrument includes only those requests for information that the Department believes is necessary for basic administration of the included programs. Without this information, the Department cannot work effectively with state and local officials and educators and other member of the public to promote the most effective use of program funds provided under the covered ESEA programs and Goals 2000. Instead, the Department and the public will have to continue relying on program reporting instruments that are prepared for each individual program.
Finally, for Title I, Parts A, C and D as well as Goals 2000, the data elements that are included in the appendix of the consolidated reporting instrument merely reiterate information already contained in existing OMB-approved performance reports. The data elements included in the appendix for Title III reflect the current elements now under OMB review. Data elements for Title II and Title VI are new. Those for Title II reflect the Department's need for basic information under that program, and a significant decrease in the collection of information from Title II reporting instruments used in prior years. The data elements for Title VI in the appendix (which modify the existing OMB-approved reporting form) are intended to clarify (and hence improve), without increased burden, the value of data provided under that program.
d. Legal and Administrative Requirements Necessitating this Collection. SEAs would use this consolidated reporting instrument for reporting on program performance and uses of funds during the 1998-99 school year. Reporting at the close of this year is required by statute under Goals 2000 and Title VI. Copies of the pertinent statutes requiring a collection of information are attached.
e. Initial Information Collection for 1998-99 School Year. The first part of the consolidated reporting instrument contains a series of questions that SEAs would answer in narrative form on their progress in implementing their approved ESEA consolidated plans. This information is important to the Department's ability to administer the ESEA and Goals 2000 programs in a way that focuses on their interrelationships, and to work with each State to ensure that federal program funds are used effectively. However, the Department does not now collect information of this kind from States. SEAs would submit this information to the Department for the first time in December 1998. In December 1999, SEAS would also submit this information, along with the programmatic information requested in the remainder of the reporting instrument. (After a final consolidated reporting instrument for the 1998-99 school year is finalized, the Department intends to continue discussions with the public about the content of a possibly revised instrument to be proposed, under procedures mandated by the Paperwork Reduction Act, for the 1999-2000 school year.)
2. The Department will use the information on uses of program funding, program beneficiaries, and efforts to implement consolidated planning in a number of important ways. These include:
working with States, schools and school districts on how ESEA and Goals funds might be used more effectively;
helping the Department to measure success in meeting performance objectives for the included programs that it has established pursuant to the Government Performance and Results Act; and
informing the Department's reporting to Congress and to the public on the operation of the included programs.
3. Reporting on uses of program funds during the 1997-98 and 1998-99 school years is expected to be by traditional paper means. But the Department's National Center for Education Statistics and its contractor, Westat, have begun work with up to ten States on a voluntary basis to pilot-test the viability of States (and school districts) using electronic means to respond to the data elements contained in the consolidated reporting instrument. The results of this pilot test will allow the Department to continue to work with these and other States to permit wide-scale electronic submissions as soon as feasible.
4. This information collection does not duplicate any information that the Department now has or that is otherwise available. Indeed, by consolidating individual program reporting into a single instrument, the Department would reduce burden caused by the multiplicity of different program reporting instruments and requirements.
As noted in response to #1, above, for those states that have submitted consolidated state plans this consolidated reporting instrument would --
replace individual program performance reports that OMB has approved for use under ESEA, Title I, Parts A, C and D, Title VI and Goals 2000; and
Include all reporting elements for individual state reports states to be submitted, after OMB approval, under ESEA, Title II and Title III.
5. Neither small businesses nor small entities are affected by this collection.
6. If the information is not collected through the consolidated reporting instrument, the Department will have to continue collecting performance and other information from States on a program-by-program basis; will not have a means for having States report on their progress implementing their approved consolidated state plans; and will be unable to respond positively to the requests of many state officials that the Department collect program information on a consolidated basis.
7. No special circumstances exist that would cause this information to be collected in any of the ways listed under #7.
8. Department officials have met with representatives of several state departments of education at a meeting in April, 1997 convened by the CCSSO to discuss steps that the Department proposed to undertake to respond to state officials' requests for a consolidated reporting instrument. Since then, Department officials also have met with state representatives on the CCSSO's education information advisory group to discuss the Department's progress in developing such an instrument.
The Department will use the initial 60-day period for public comment under the Paperwork Reduction Act for a period of substantive discussion with state officials (and others) about the Department's proposed reporting form. These discussions will include, but not be limited to, a series of regional meetings to be convened by the National Center for Education Statistics that will focus on how to improve the consolidated instrument and further reduce the burden on States and subgrantees.
9. No payment or gift of any kind will be provided to respondents.
10. No assurance of confidentiality pertaining to this information will be provided to respondents.
11. The information collection does not include questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
12. For calendar year 1998: SEAs would respond only to the narrative questions in the first portion of the consolidated reporting form. For 1998, each SEA (for 50 states and DC and Puerto Rico) is estimated to need an average of [1] hour to complete the reporting instrument. The average hourly rate for each of the 52 SEAs is estimated to be [$20.00]. The total average cost to SEAs for this information collection therefore estimated to be [$$1,040].
For the 1998-99 school year: When SEAs would respond to the entire consolidated reporting instrument, each SEA (for 50 states and DC and Puerto Rico) is estimated to need an average of [1] hour to complete the reporting instrument. The average hourly rate for each of the 52 SEAs is estimated to be [$20.00]. The total average cost to SEAs for this information collection therefore estimated to be [$$1,040].
In addition, each LEA and other subgrantee is estimated to need an average of [1] hour to complete the reporting instrument. The average hourly rate for each of the 15,000 local educational agencies (LEAs) and other subgrantees is estimated to be [$20.00]. The total average cost for this information collection therefore estimated to be [$300,.000].
The total cost of this information collection is estimated to be [$301,040].
[NOTE: The estimates of burden hours and costs set forth above are placeholders. Actual hours of burden and cost will be determined on the basis of discussions with the public that will occur during the period for public comment on the proposed consolidated reporting instrument.]
13. This information collection does not require the use of any capital equipment. For reporting after the 1998-99 school year, respondents will incur nominal start-up costs, as estimated below, to develop forms or other formats to provide information about services offered and populations served.
Professional staff [$1]Clerical staff [$1]
[NOTE: The estimates of burden hours set forth above are placeholders. Actual estimates of cost will be determined on the basis of discussions with the public that will occur during the period for public comment on the proposed consolidated reporting instrument.]
14. Annual cost to the Federal government:
1998 1999 and 2000
Design/development/review [$1] [$1]
Printing/Mailing: [$1] [$1]
Collection, analysis, dissemination [$1] [$1
Contract for editing, publication [$1] [$1]
[NOTE: The estimates of burden hours set forth above are placeholders. Actual estimates of cost will be determined on the basis of discussions with the public that will occur during the period for public comment on the proposed consolidated reporting instrument.]
15. Except for reporting changes and adjustments noted in response to #1, above, this is a new information collection that has no program changes or adjustments.
16. SEAs will be asked to submit their consolidated reporting instrument to the Department on or before December 1, 1999 (and responses to the narrative questions in the first part of the instrument on or before December 1, 1998). As is customary with program performance reports for ESEA state formula grant programs, the Department expects to contract with a private research firm for the analysis of the data that states provide in their consolidated reporting instruments. Final reports would be made available to the states, Congress, and the public at large.
17. Approval to not display expiration date has not been requested.
18. No exceptions were identified.