SUPPORTING STATEMENT

A. Justification

> 1\. Explain the circumstances that make the collection of information
> necessary. Identify any legal or administrative requirements that
> necessitate the collection.

Section 487(c) of the Higher Education Act (HEA) of 1965 as amended
requires that the Secretary prescribe regulations to ensure that any
funds postsecondary institutions receive under the HEA are used solely
for the purposes specified in and in accordance with the provision of
the applicable programs. The concept of this federal gatekeeping has a
long history, originating in 1952. However, as a result of abuses by
institutions in the Title IV programs, the HEA amendments of 1992
significantly increased ED's gatekeeping responsibilities. In general,
the statutory provisions tightened the eligibility requirements for
institutions participating in the student financial assistance programs
authorized under Title IV of the HEA.

In 1994, the Secretary amended the regulations governing institutional
eligibility under the HEA in accordance with the statutory requirements.
The Institutional Eligibility regulations govern the initial and
continuing eligibility of postsecondary educational institutions
participating in the student financial assistance program authorized by
Title IV of the Higher Education Act (HEA).

Part H, Subpart 3, Section 498 of the HEA of 1965, as amended, gives the
Secretary of Education the responsibility for determining qualifications
of institutions of higher education to participate in programs under the
HEA.

To comply with this requirement, Section 498(b) of the Higher Education
Act, specified that the Secretary prepare and prescribe a single
application form. The Department developed the Application for Approval
to Participate in Federal Student Financial Aid Programs (ED Form
E40-34P) to comply with the statutory requirements of collecting
necessary information under the HEA.

An institution must use this Application to apply for approval to be
determined to be eligible and if the institution wishes, to participate,
to expand its eligibility or continue to participate in the Title IV
programs. An institution must also use the application to report certain
required data as part of its recordkeeping requirements contained in the
regulations under 34 CFR Part 600 (Institutional Eligibility under the
Higher Education Act of 1965, as amended).

The Department uses the information reported on the Application in its
determination of whether an institution meets the statutory and
regulatory requirements.

Listed below are the specific regulations that require an institution to
apply to the Department of Education for:

-   An eligibility determination and if requested, certification to
    participate;

-   continued eligibility to participate;

-   reporting changes made to the institution, as required; and

-   expansion of its current approval.

Section 600.20 - [Application procedures]{.underline} - requires an
institution that wishes to participate in any title IV program, to apply
for initial eligibility, as well as continued or expanded approval
including new locations or new programs.

Section 600.21 -- [Updating Application Information]{.underline} -
requires an institution to notify the Secretary of any changes to
certain information, including its name, address, etc.

Section 600.31 - [Change in ownership resulting in a change of
control]{.underline} - requires an institution that has undergone a
change in ownership that results in a change in control to demonstrate
to the Secretary that it meets the requirements of an eligible
institution in order to continue to be eligible. The 1998 Amendments
provided that the Secretary may continue the institution's participation
on a provisional basis provided that the institution under the new
ownership submits a materially complete application that is received by
the Secretary no later than 10 business days after the change occurs.

In addition to the information above, the application is also the place
where schools can report other information to us that it needs or wants
us to know. Specifically, the Higher Education Act of 1965 (HEA), as
amended, requires an

institution of postsecondary education to file a disclosure report with
the Secretary on January 31 or July 31 of each year, containing certain
information about gifts received from or contracts entered into with
foreign sources or about ownership or control of the institution by a
foreign source

(Section 1209, 20 U.S.C. 1145d).

Schools also needed a place to be report the official that is the
school's destination point administrator and an additional official
authorized to certify

FFEL Loan applications. We have added fields to enter that information.
Additional corporate and unincorporated owner type choices were added
for schools to select. We are now requesting the owner's home address.
We also removed the words "within the past ten years" from the question
about whether the person or entity that owns or controls the institution
ever held a position or now owns or owned another institution (question
25). And we are now asking the school if there is any liability
currently owned to the Department that was established during the period
of ownership or position held.

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.

School Participation Management (SPT) (which is the organization within
the Department of Education, Federal Student Aid) reviews and analyzes
the information reported on the application and makes a determination on
the institution's request. SPT's decision is based not only on the
information reported by the institution on the application, but also on
other information in its possession. SPT makes its decision using a case
team approach to its work processes. This allows SPT to evaluate a
school based on a total picture of integrated institutional information.

SPT's decision includes determining that the institution is:

-   Designated an eligible institution;

-   Certified or recertified to participate in Title IV programs;

-   Approved, for Title IV purpose, to expand its current approval (new
    location or programs, etc.);

-   In compliance with the required reported requirements (name changes,
    address changes, etc.); or

-   Notified that its request is denied.

> 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. Also
>
> describe any consideration of using information technology to reduce
> burden.

The data submitted by an institution during the first round of
recertification became part of the Postsecondary Education Participants
System (PEPS), the Department of Education\'s computerized information
management system of institutional data.

SPT designed a computerized version of the Application. An institution
accesses the Application using the Internet. Many of the questions on
the Application are pre-populated using information the institution
submitted on its previous Application and SPT stored in PEPS.
Pre-populating the answers to the questions alleviates the need for the
institution to enter a response to every question. Instead, the
institution needs to review the information and if necessary, update it.
(Note: Certain questions must be answered each time an institution
submits a complete application.) Once the institution has updated its
Application, it submits it to the School Participation Management
(SPT/SFA) via the Internet. The institution receives immediate
notification of its receipt by the Department. Once the Department has
made a decision on the Application, the information from the Application
is migrated to PEPS electronically, thus reducing the Department's
burden for data entry and increasing the accuracy of the data in PEPS.

The electronic application has additional features such as:

-   hot links to take you from one area to another in one mouse click;

-   skip features that let you skip questions or a section if it does
    not apply to the institution;

-   edits that help the institution not miss a required question or
    enter the wrong type of information;

-   help section;

-   ED contacts, both phone numbers and e-mail address. The e-mail
    address is actually a hot link directly to SPT or PEPS and allows an
    institution to submit its questions to the Department
    electronically; and

-   A status page that lets the institution know where the application
    is in SPT's review process.

The Department/Office of Postsecondary Education has a database list
that identifies postsecondary educational institutions and programs that
are accredited. OPE will be expanding this list to include the necessary
information SPT needs to determine if an institution, its programs and

locations are covered by the accreditor. This will allow SPT to get use
this information instead of having the school submits the information.

> 4\. Describe efforts to identify duplication.

There is no duplication of records that an institution must maintain.
The Application for Approval to Participate in Federal Student Financial
Aid Programs provides the initial contact of an institution seeking to
participate in Federal programs administered by Federal Student Aid. A
new institution will not have provided similar information to any other
office in the Department. A continuing institution may have provided
similar information as part of the Integrated Postsecondary Education
Data System survey, but it is not the same.

> *5.* If the collection of information involves small businesses or
> other small entities, describe the methods used to minimize burden.

The information collection does not impact small businesses or other
small

entities.

> 6\. Describe the consequence 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.

Section 498(g) of the HEA required that the Department recertify all
eligible institutions that wished to continue to participate in the
Title IV programs. The maximum time period the Secretary may approve an
institution was up to 4 years. The 1998 HEA amendments expanded the
approval period to 6 years.

The statute also provides that the Secretary may provisionally certify
new institutions, institutions that change ownership, and institutions
with questionable financial responsibility and administrative capability
for a period of time from one to three years. The Department uses this
tool to allow for increased monitoring of institutions with no track
record and institutions with documented problems. If information were
collected less frequently, ED would not be in compliance with the HEA
and would not be using the tools Congress provided to improve
gatekeeping capability.

Note that in most cases, it is no longer necessary for an institution to
submit a complete application to report activities such as change in
name or address, a change in level of course offering or a change in
measurement of program length. Instead, with the Application,
institutions need to update only the questions on the Application that
are affected by the change. Thus, while the frequency with which
institutions must report certain changes has not changed and cannot,
because they are vital pieces of information relative to the
institution\'s eligibility, the reporting burden for those actions is
decreased significantly.

If the collection is not conducted, a new institution would not be able
to participate in Title IV programs, a currently approved institution
would not be able to participate past its approved expiration date, meet
the notification and recordkeeping requirements or be able to expand its
eligibility. Further, the Department would lose a valuable gatekeeping
tool.

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;

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-   requiring respondents to submit more than an original and two copies
    of any document;

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-   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 that can be generalized to the
    universe of study;

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-   requiring the use of a statistical data classification that has not
    been reviewed and approved by OMB;

-   that includes a pledge of confidentiality that its 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 which 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 of information does not meet any of the special
circumstances described.

8.  If applicable, provide a copy and identify the date and page number
    of publication in the Federal Register of the agency's notice,
    required by 5 CFR 3120.8(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.

ED published the Application for Approval to Participate in Federal
Student Financial Aid Programs in the Federal Register on August 11,
2005 as required by 5 CFR 3120.8(d). The responses we received from the
public were for the most part "No comment". One responder did indicated
that he found the process to be easy now. He further indicated that this
is an important process but did not have any other suggestions for the
form or process.

> Describe efforts to consult with persons outside the agency to obtain
> their views on the availability of data, frequency of collection, the
> clarity of instructions and record keeping, disclosure, or reporting
> format (if any), and on the data elements to be recorded, disclosed or
> reported.

Enormous public interest was created when the Application was received
by schools in the first cohort selected for recertification. Hundreds of
schools and other interested parties provided their comments over the
telephone, by fax, through the mail and on the internet. From this group
a smaller number of well-qualified individuals participated in a focus
group to work with the Department as it addressed the higher education
community's concerns about complexity, length and burden. The
application was then reengineered. The goals for the form were clarity,
accuracy and simplicity while still allowing the Department to improve
gatekeeping, have a more efficient process, receive more reliable
information from the institution and provide for institutional
accountability inherent in the questions. The Application was then
"field tested".

It is apparent that the redesign group was successful in producing a
valuable tool that asks clear questions that do not put a burden on an
institution to

answer. With the exception of the minor changes to the Application, the
information requested in the form currently up for OMB approval was in
the previous (reengineered) edition of the Application. The Application
has been widely accepted by the community and in use since September of
1996.

The Department holds Electronic Access Conferences in the fall. The
Application for Approval to Participate in Federal Student Financial Aid
Programs is one of the processes that is featured at these conferences.

Responses we have received from school officials have been extremely
positive. They find the questions in the Application to be clear and the
process to complete the application simple.

In addition, the Department officials routinely attend state, regional
and professional association meetings and conferences. Typically, the
Department participates in these types of forum that presents an
opportunity to receive feedback from the higher education community
regarding its policies and procedures including the Application and the
recertification process. The feedback that has been received has been
overwhelming approval of the application as one that asks clear
questions that do not burden the institution.

In addition to attending meetings and conferences, the Department also
receives feedback from the community via telephone calls and e-mails.
The Department has been responsive to comments and suggestions from the
community. For example, while the Department gave particular emphasis to
design the electronic Application to be \"user friendly", based on
feedback from the community, we continue to make changes to improve the
electronic flow of the application, which made it even easier to use.

9.  Explain any decision to provide any payment or gift to respondents
    other than renumberation of contractors or grantees.

NONE

10. Describe any assurance of confidentiality provided to respondents
    and the basis for the assurance in statute, regulation, or agency
    policy.

The information that is being requested is mandated by the Higher
Education Act and Title 31 as amended by Section 31001 of Public Law
104-134 of the Debt Collection Improvement Act of 1996.

Section 498A(a)(3) of the HEA requires the Secretary to establish a
central database of information on institutional accreditation,
eligibility, and certification that include all information available to
the Department.

Section 498A(c) instructs the Secretary to make this information
available to all institutions of higher education, guaranty agencies,
states, and other organizations participating in the programs authorized
under Title IV of the HEA. Therefore, ED cannot make any assurances of
confidentiality to respondents.

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.

This collection does not ask questions of a sensitive nature.

> 12\. Provide estimates of the hour burden of the collection of
> information.

+--------------+-----------------------+-------------------+---------+
| 34 CFR       | Number of             | Hours Required to | Total   |
|              | Applications Reported | Collect and       | Hours   |
| Requirement  | Annually[^1]          | Report            |         |
+==============+=======================+===================+=========+
| 600.20       | 130                   | 17                | 2,210   |
| Initial      |                       |                   |         |
+--------------+-----------------------+-------------------+---------+
| 600.20       | 1500                  | 10                | 15,000  |
| recert       |                       |                   |         |
+--------------+-----------------------+-------------------+---------+
| 600.20       | 105                   | 15                | 1,575   |
|              |                       |                   |         |
| foreign      |                       |                   |         |
| recert       |                       |                   |         |
+--------------+-----------------------+-------------------+---------+
| 600.20       | 900                   | 0.5               | 450     |
|              |                       |                   |         |
| expand       |                       |                   |         |
| eligibility  |                       |                   |         |
+--------------+-----------------------+-------------------+---------+
| 600.21       | 600                   | 10                | 6,000   |
+--------------+-----------------------+-------------------+---------+
| 600.31       | 150                   | 1                 | 1,500   |
+--------------+-----------------------+-------------------+---------+
| Total        | 3385                  |                   |         |
+--------------+-----------------------+-------------------+---------+
| Total Hour   |                       |                   | 26,085  |
| Burden of    |                       |                   |         |
| Collection   |                       |                   |         |
| Information  |                       |                   |         |
+--------------+-----------------------+-------------------+---------+

20. refers to applications submitted by institutions for initial
    approval and recertification. This requirement has been broken down
    into four lines since it takes a new school longer to complete an
    application than one that is submitting a recertification
    application. This is especially true now that an institution
    submitting an application for recertification does so using the
    electronic application. As explained earlier, the electronic
    application is pre-populated with information the Department
    previously received from the institution. An institution applying
    for expansion of its current eligibility only needs to complete the
    portion of the application that applies to the expansion, so it
    takes much less time to complete that type of application.

21. refers to the requirement that institutions must update the
    Department regarding certain required information such as changes to
    the institution's name or address.

600.31 refers to applications submitted for change in ownership that
result

in the change of control.

This burden information was estimated based on recent (Spring 2005)
conversations with institutions that have submitted applications for
these various purposes.

Provide estimates of annualized cost to respondents for the hour burdens
for collection of information, identifying and using appropriate wage
rate categories.

Initial Applicant

+---------------+------------+-------------+-------------+-----------+
| Position      | Wage Rate  | Cost Per    | Hours       | Cost      |
|               |            |             | Expended    |           |
|               | Category   | Hour        |             | Burden    |
+---------------+------------+-------------+-------------+-----------+
| Senior        | \$126,017  | \$70        | 1           | \$70      |
|               |            |             |             |           |
| Administrator |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Professional  | \$57,955   | \$30        | 16          | \$480     |
|               |            |             |             |           |
| Staff         |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Total         |            |             | 17          | \$550     |
+---------------+------------+-------------+-------------+-----------+

Recertification

+---------------+------------+-------------+-------------+-----------+
| Position      | Wage Rate  | Cost Per    | Hours       | Cost      |
|               |            |             | Expended    |           |
|               | Category   | Hour        |             | Burden    |
+---------------+------------+-------------+-------------+-----------+
| Senior        | \$126,017  | \$70        | 1           | \$70      |
|               |            |             |             |           |
| Administrator |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Professional  | \$57,955   | \$30        | 9           | \$270     |
|               |            |             |             |           |
| Staff         |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Total         |            |             | 10          | \$340     |
+---------------+------------+-------------+-------------+-----------+

Recertification of Foreign Institution

+---------------+------------+-------------+-------------+-----------+
| Position      | Wage Rate  | Cost Per    | Hours       | Cost      |
|               |            |             | Expended    |           |
|               | Category   | Hour        |             | Burden    |
+---------------+------------+-------------+-------------+-----------+
| Senior        | \$126,017  | \$70        | 1           | \$70      |
|               |            |             |             |           |
| Administrator |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Professional  | \$57,955   | \$30        | 14          | \$420     |
|               |            |             |             |           |
| Staff         |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Total         |            |             | 15          | \$490     |
+---------------+------------+-------------+-------------+-----------+

Update Changes

+---------------+------------+-------------+-------------+-----------+
| Position      | Wage Rate  | Cost Per    | Hours       | Cost      |
|               |            |             | Expended    |           |
|               | Category   | Hour        |             | Burden    |
+---------------+------------+-------------+-------------+-----------+
| Senior        | \$126,017  | \$70        | .20         | \$14      |
|               |            |             |             |           |
| Administrator |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Professional  | \$57,955   | \$30        | .30         | \$ 9      |
|               |            |             |             |           |
| Staff         |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Total         |            |             | .50         | \$23      |
+---------------+------------+-------------+-------------+-----------+

Change in Ownership

+---------------+------------+-------------+-------------+-----------+
| Position      | Wage Rate  | Cost Per    | Hours       | Cost      |
|               |            |             | Expended    |           |
|               | Category   | Hour        |             | Burden    |
+---------------+------------+-------------+-------------+-----------+
| Senior        | \$126,017  | \$70        | 1           | \$70      |
|               |            |             |             |           |
| Administrator |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Professional  | \$57,955   | \$30        | 9           | \$270     |
|               |            |             |             |           |
| Staff         |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Total         |            |             | 10          | \$340     |
+---------------+------------+-------------+-------------+-----------+

Request to Expand current approval

+---------------+------------+-------------+-------------+-----------+
| Position      | Wage Rate  | Cost Per    | Hours       | Cost      |
|               |            |             | Expended    |           |
|               | Category   | Hour        |             | Burden    |
+---------------+------------+-------------+-------------+-----------+
| Senior        | \$126,017  | \$70        | .40         | \$28      |
|               |            |             |             |           |
| Administrator |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Professional  | \$57,955   | \$30        | .60         | \$ 18     |
|               |            |             |             |           |
| Staff         |            |             |             |           |
+---------------+------------+-------------+-------------+-----------+
| Total         |            |             | 1           | \$46      |
+---------------+------------+-------------+-------------+-----------+

Annualized Cost for Collection of Information

+------------+----------------------+------------------+--------------+
| 34 CFR     | Number of            | Cost per         | Total Burden |
|            | Institutions         | Institution      |              |
| R          | Reporting            |                  |              |
| equirement | Annually[^2]         |                  |              |
+============+======================+==================+==============+
| 600.20     | 130                  | \$550            | \$71,500     |
| Initial    |                      |                  |              |
+------------+----------------------+------------------+--------------+
| 600.20     | 1500                 | \$340            | \$510,000    |
| recert     |                      |                  |              |
+------------+----------------------+------------------+--------------+
| 600.20     | 105                  | \$490            | \$51,450     |
|            |                      |                  |              |
| foreign    |                      |                  |              |
| recert     |                      |                  |              |
+------------+----------------------+------------------+--------------+
| 600.20     | 900                  | \$46             | \$41,400     |
|            |                      |                  |              |
| expand     |                      |                  |              |
| e          |                      |                  |              |
| ligibility |                      |                  |              |
+------------+----------------------+------------------+--------------+
| 600.21     | 600                  | \$23             | \$13,800     |
+------------+----------------------+------------------+--------------+
| 600.31     | 150                  | \$340            | \$51,000     |
+------------+----------------------+------------------+--------------+
| Total Hour |                      |                  | \$739,150    |
| Burden of  |                      |                  |              |
| Collection |                      |                  |              |
| I          |                      |                  |              |
| nformation |                      |                  |              |
+------------+----------------------+------------------+--------------+

13\. Provide an estimate of the total annual cost burden to respondents
or recordkeepers resulting from the collection of information.

There is no cost burden to respondents or recordkeepers resulting from
the information collection other than shown in items 12 and 14.

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
    and any other expense that would not have been incurred without this
    collection of information.

REVIEWERS COSTS: Identifies the amount of time for a reviewer to examine
the information submitted on the application and the supporting
documentation. This information is then reported out to the case team
for a full decision on the institution's application.

+-----------+--------------+----------+---------+---------+----------+
| 34 CFR    | Number of    | Hours    | Total   | Average | Cost per |
|           | Institutions | Required | Hours   |         | CFR      |
| Re        | Reporting    | for ED   |         | Hourly  | Req      |
| quirement | Annually[^3] | Review   |         |         | uirement |
|           |              |          |         | Wage    |          |
+===========+==============+==========+=========+=========+==========+
| 600.20    | 130          | 2        | 260     | \$34    | 8,840    |
| Initial   |              |          |         |         |          |
+-----------+--------------+----------+---------+---------+----------+
| 600.20    | 1,500        | 2        | 3,000   | \$34    | 102,000  |
| recert    |              |          |         |         |          |
+-----------+--------------+----------+---------+---------+----------+
| 600.20    | 105          | 3        | 315     | \$34    | 10,710   |
| foreign   |              |          |         |         |          |
| recert    |              |          |         |         |          |
+-----------+--------------+----------+---------+---------+----------+
| 600.20    | 900          | 1        | 900     | \$34    | 30,600   |
|           |              |          |         |         |          |
| expand    |              |          |         |         |          |
| el        |              |          |         |         |          |
| igibility |              |          |         |         |          |
+-----------+--------------+----------+---------+---------+----------+
| 600.21    | 500          | .5       | 250     | \$34    | 8,500    |
+-----------+--------------+----------+---------+---------+----------+
| 600.31    | 150          | 2        | 300     | \$34    | 10,200   |
+-----------+--------------+----------+---------+---------+----------+
| Total     |              |          |         |         | \        |
| Cost for  |              |          |         |         | $170,850 |
| ED'       |              |          |         |         |          |
| review of |              |          |         |         |          |
| the       |              |          |         |         |          |
| Ap        |              |          |         |         |          |
| plication |              |          |         |         |          |
| In        |              |          |         |         |          |
| formation |              |          |         |         |          |
+-----------+--------------+----------+---------+---------+----------+

Costs to maintain and improve electronic application: \$228,000

Total annualized cost to the Federal government: \$398,850

15. Explain the reasons for any program changes or adjustments reported
    in items 13 or 14 of the OMB Form 83-1.

The form, item 13 reflects an increase of approximately of 5,255 hours
reported and 415 annual responses. The increase is due to institution
submitting additional applications to the Department of Education. The
institution report update information (for example, new officials,
changes to the name and address of the institution) as well as applying
for expansions of the current approvals (for example applying for new
programs and locations).

16. For collection of information whose results will be published,
    outline plans for tabulations, 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, completing of report, publications dates,
    and other actions.

Application information is not expected to be published.

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 Department has and will continue to display on the form, the
expiration date for the OMB approval as required.

18. Explain each exception to the certification statement identified in
    Item 19 "Certification for Paperwork Reduction Act Submissions", of
    OMB Form 83-1

There are no exceptions to the certification statement.

19\. Collections of Information Employing Statistical Methods.

There is no collection of information employing statistical methods for
this application.

[^1]: Some institutions report more than once a year.

[^2]: Some institutions report more than once a year.

[^3]: Some institutions report more than once a year.