Overview
Title
Agency Information Collection Activities; Comment Request; Example Application for the Emergency Assistance to Non-Public Schools Program
Agencies
ELI5 AI
The Department of Education wants to check if a new form they need for giving money to private schools is important and not too hard to fill out, but they want to do it quickly because of COVID-19. They're asking people to say if they agree or not by March 22, 2021.
Summary AI
The Department of Education is asking for an emergency review to collect information for the Emergency Assistance to Non-Public Schools (EANS) program under the COVID-19 relief act. This program aims to provide funds to non-public schools affected by the pandemic. The department is inviting public comments on whether this information collection is necessary, its timeliness, accuracy, and how to minimize the burden on participants. Public comments will be accepted until March 22, 2021.
Abstract
In accordance with the Paperwork Reduction Act of 1995, ED is requesting the Office of Management and Budget (OMB) to conduct an emergency review of a new information collection.
Keywords AI
Sources
AnalysisAI
The document from the Department of Education presents a request for an emergency review of a new information collection initiative related to the Emergency Assistance to Non-Public Schools (EANS) program under the COVID-19 relief act. This program seeks to allocate funds to non-public schools that have been adversely impacted by the ongoing pandemic. To facilitate this, the Department aims to collect necessary information from these schools and is soliciting comments from the public to refine this process.
General Summary
In alignment with the Paperwork Reduction Act of 1995, the Department is seeking to expedite the process of collecting data necessary for the allocation of EANS funds. This request includes a broad invitation for public feedback on key issues such as the necessity, accuracy, and potential burden of the proposed information collection. Comments are welcomed through March 22, 2021. The proposed collection targets state, local, and tribal governments, with an estimated annual response count of 20,000 and 40,000 burden hours.
Significant Issues and Concerns
One of the notable issues with this proposal is the request for an emergency review, which, while aiming to fast-track the necessary procedures, raises concerns about bypassing the usual scrutiny that ensures the necessity and potential burden of such collections are fully addressed. The estimated figures for annual responses and associated burden hours indicate a potentially significant impact on respondents. Yet, the document does not fully elaborate on the reasons justifying this request beyond the general requirements of the CRRSA Act.
Moreover, the language suggesting states can either use the provided example application or create their own may result in inconsistencies in application methodologies across different states, potentially leading to confusion or inefficiency in the program’s implementation. The term "example application" also leaves room for ambiguity regarding how states should implement or adjust it to suit their needs.
Additionally, the document lacks any criteria that would be used to evaluate the effectiveness or efficiency of the information collection process once it is implemented, leaving an essential part of program oversight unaddressed.
Public Impact
For the general public, particularly those involved with non-public educational institutions, this document implies an added administrative requirement necessary to access financial support. While the initiative's intent is to provide timely assistance to schools affected by the pandemic, the process may impose a demanding workload for those responsible for submitting the required information.
Impact on Specific Stakeholders
Non-public schools, which stand to benefit from the financial support offered, may face challenges in terms of the administrative effort needed to complete the application process. The necessity to quickly gather and submit accurate information might be burdensome, particularly for smaller institutions with limited resources. On the other hand, states and local education authorities tasked with managing the receipt and evaluation of these applications may find themselves navigating inconsistent application formats due to the flexibility given to states to use or amend the example application.
In summary, while the document proposes an essential mechanism to allocate funds efficiently to schools in need, the execution details raise questions regarding procedural rigor and potential inconsistencies. These factors could adversely affect both the recipients and those overseeing the process, necessitating a careful review and further clarification to ensure the intended benefits are realized effectively.
Issues
• The document requests an emergency review of an information collection, which might bypass the typical review process, potentially leading to inadequate scrutiny of the necessity or burden of the information collection.
• The total estimated number of annual responses (20,000) and burden hours (40,000) might indicate a significant burden on respondents. The necessity and justification for this level of burden should be carefully scrutinized.
• The document does not indicate why an emergency clearance is needed beyond the general requirements set by the CRRSA Act, leaving room for questioning if the urgency is justified.
• The language regarding the alternative options for states ('States are not required to use this application and may create their own.') may lead to inconsistency in application methods, potentially causing confusion or inefficiencies.
• The use of the term 'example application' could be ambiguous if it is not clear how it should be utilized or adapted by each state.
• The document does not specify any criteria for evaluating the effectiveness or efficiency of the information collection process once implemented.