Supporting Statement for Paperwork Reduction Act Submissions

**2009-2010 Free Application for Federal Student Aid (FAFSA)**

 

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

Public Law 89-329, Sections 401-495, The Higher Education Act of 1965 as
amended (HEA), mandates that the Secretary of Education "...produce,
distribute and process free of charge a common financial reporting form
to be used to determine the need and eligibility of a student for
financial assistance." Section 483 of the HEA mandates that "the
Secretary shall...use a common, simplified reapplication form..." that
enables applicants who applied in previous years to submit a renewal
application.

Federal Student Aid, an office of the U.S. Department of Education
(hereafter "the Department"), subsequently developed the Free
Application for Federal Student Aid (FAFSA) to collect the data
necessary to determine a student's eligibility to receive Title IV, HEA
program assistance. For students that have previously submitted a FAFSA,
the Department developed a Renewal FAFSA that contains certain constant,
preprinted data that the applicant need change only if the information
has changed since the previous FAFSA submission. The Renewal FAFSA
(renamed Pre-Filled FAFSA for 2009-2010) reduces the burden on
applicants by presenting the information they previously submitted;
enabling the applicant to provide changed data.

The FAFSA is used to determine student eligibility for the following
Title IV, HEA, federal student assistance programs: the Federal Pell
Grant Program; the Campus-Based programs (Federal Supplemental
Educational Opportunity Grant (FSEOG), Federal Work-Study (FWS), and the
Federal Perkins Loan Program); the William D. Ford Federal Direct Loan
Program; the Federal Family Education Loan Program; the Academic
Competitiveness Grant; the National Science and Mathematics Access to
Retain Talent (SMART) Grant; and the Teacher Education Assistance for
College and Higher Education (TEACH) Grant Program.

**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.**

As in the past, the 2009-2010 FAFSA will be made available to the public
in both electronic and paper form. (For a description of each, see
Question 12). Because the submission of paper FAFSA forms continues to
decline dramatically, the Department is considering the elimination of
the pre-printed paper FAFSA for the 2010-2011 processing cycle. In
anticipation of this change, the Department has developed a FAFSA in
portable document format (PDF) which individuals and institutions may
access via the Department's web site. The FAFSA PDF is 'screen fillable'
or users may opt to print out blank copies that can be filled out by
hand. Applicants that fill out their FAFSA PDF on a computer will not
have the option to save that information due to concerns about the
security and privacy of the applicant's FAFSA data. The Department has
worked closely with the higher education community to increase awareness
of and access to the FAFSA PDF for students that do not have consistent,
reliable access to the Internet, but who could obtain copies of the
FAFSA PDF from a school or could access the Department's web site for a
period of time sufficient to view and print a FAFSA PDF.

The purpose of the FAFSA is to collect personal and financial data from
current or prospective students in order to determine a student's
eligibility for financial aid and to perform a need analysis as
described in Section 471 of the HEA. The need analysis results in an
Expected Family Contribution (EFC) that postsecondary educational
institutions use when determining the types and amounts of both federal
and non-federal financial aid a student will receive. The information a
student is required to provide on the FAFSA varies based upon his or her
life circumstances. There are three regular EFC formulas for: dependent
students, independent students without dependents other than a spouse,
and independent students with dependents other than a spouse. The EFC
formula for a dependent student uses parental data, and the two for
independent students do not. Therefore, the burden hour calculation
varies based upon applicant type. (For burden hour estimates for
applicant type by product, see Question 12)

After completing the FAFSA, the student submits the form to the Central
Processing System (CPS) via the Internet or via the postal service. The
CPS processes the data from the FAFSA, sends the student a Student Aid
Report (SAR), and sends to schools the student has listed on the FAFSA
an electronic Institutional Student Information Record (ISIR). To assist
states in the awarding of state financial aid, an ISIR is also sent to
the student's state of legal residence as well as the states of the
schools the student has listed on the FAFSA. Financial aid
administrators at those schools, or other Title IV participating schools
selected by the student, may award federal student assistance on the
basis of either the student\'s valid SAR or ISIR, both of which contain
a student\'s identification information, all the application data, and
the official EFC as calculated by the CPS.

The EFC is calculated in accordance with the statutory formula in Part F
of the HEA and is intended to indicate a student's ability (and for
dependent applicants, his or her family\'s ability) to contribute toward
the student\'s cost of attending an institution of higher education. The
following data elements are considered in determining the EFC:

1)  The available income of (A) the student and the student\'s spouse,
    or (B) the student and the student\'s parents, in the case of a
    dependent student;

2)  The number of dependents in the family of the student;

3)  The number of dependents in the family of the student (excluding the
    parents) who are enrolled or accepted for enrollment, on at least a
    half-time basis, in a degree, certificate, or other program leading
    to a recognized educational credential at an institution of higher
    education that is an eligible institution in accordance with the
    provisions of Section 487 and for whom the family may reasonably be
    expected to contribute to their postsecondary education;

4)  The net assets of (A) the student and the student's spouse, or (B)
    the student and the student\'s parents, in the case of a dependent
    student;

5)  The marital status of the student;

6)  The age of the older parent, in the case of a dependent student; and

7)  Any additional expenses incurred (A) in the case of a dependent
    student, when both parents of the student are employed or when the
    family is headed by a single parent who is employed, or (B) in the
    case of an independent student, when the student is married and the
    student\'s spouse is employed or when the employed student qualifies
    as a surviving spouse or as a head of household under section 2 of
    the Internal Revenue Code of 1986.

The Secretary of Education uses a Simplified Needs Test (SNT) for
calculating the EFC for families who meet the requirements of Part F,
Section 479 of the HEA subsection. SNT applies to families who have
adjusted gross incomes less than \$50,000 per year, and who file or are
eligible to file a form 1040A or 1040EZ. The Higher Education
Reconciliation Act of 2005 added a provision that, regardless of the
type of tax return filed, a dependent student and/or parent, or an
independent student and spouse, is eligible for the SNT if they received
benefits from any of the following five federal means-tested benefit
programs: Supplemental Security Income (SSI), Food Stamp Program, Free
or Reduced Price Lunch, Temporary Assistance for Needy Families (TANF),
and Special Supplemental Nutrition Program for Women, Infants, and
Children (WIC). The College Cost Reduction and Access Act (CCRAA)
extended the period of time for receipt of federally means-tested
benefits from 12 months prior to the start of the processing cycle to 24
months prior to the start of the processing cycle and added 'dislocated
worker' as an additional eligibility criterion.

The six components of the Simplified Needs Analysis are:

1)  Adjusted gross income;

2)  Federal taxes paid;

3)  Untaxed income and benefits;

4)  The number of family members;

5)  The number of family members (excluding the parents) in
    postsecondary education; and

6)  An allowance (A) for federal and other taxes, as defined in Section
    475(c)(2) of the HEA for parents and dependent students and in
    Section 477(b)(2) for independent students with dependents, or (B)
    for federal and local income taxes, as defined in Section 476(b)(2)
    of the HEA for independent students without dependents.

Section 479(c) of the HEA further simplifies the process by permitting
the automatic determination of an EFC of zero (Auto Zero) for families
who have adjusted gross incomes of \$30,000 or less, and who file or are
eligible to file a form 1040A or 1040EZ or who received benefits from
one of the federal means-tested benefit programs described above. Other
income and assets are not included for the purpose of calculating an
automatic zero EFC. Independent students with no dependents other than a
spouse are not eligible to receive an Auto Zero EFC determination.

The data element justification explains the purpose and use of each
element in the need analysis determination for each of these programs.
In addition to calculation of financial need for the various Title IV
programs, the FAFSA also collects data that allows for a determination
of a student's eligibility for state and school financial aid programs.
If these data elements were not collected, the Department would be
unable to make a determination of financial need and subsequently award
any Title IV, HEA program assistance, as mandated by the HEA. A majority
of states would also be greatly hindered in their calculation of state
aid to students.

There are no uses of the FAFSA other than the ones previously described.

**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.**

Section 483 of the HEA mandates that "The Secretary, in cooperation with
representatives of agencies and organizations involved in student
financial assistance, including private software providers, shall
develop an electronic version of the form." Subsequently, the Department
developed FAFSA on the Web and Renewal FAFSA on the Web (renamed
Pre-filled FAFSA for 2009-2010) as companion pieces to the paper FAFSA.
Both electronic applications are accessible via www.fafsa.ed.gov. For
the 2009-2010-award year, the Department will offer the following
electronic means of application:

***FAFSA on the Web &***

***Pre-filled FAFSA on the Web (Formerly 'FAFSA Renewal')***

Since 1998, students and their families have been able to complete and
submit an electronic application for student financial assistance via
FAFSA on the Web. In the years since, this Internet-based application,
available in both English and Spanish, has been the primary entry point
for tens of millions of students who wish to be considered for federal,
state and school financial aid. As electronic application submission
rates soared, the Department endeavored to improve FAFSA on the Web each
year. Below are some of the improvements and changes that are currently
being implemented and will enhance the applicant experience during
2009-2010.

As of January 1, 2008, the processing of electronic applications was
significantly streamlined through the use of a 'conditional PIN' that
can be assigned to an individual before, during or after the completion
of a FAFSA. The Department uses the PIN in combination with an
applicant's Social Security Number, name, and date of birth to identify
the applicant as someone who has the right to access personal
information on Federal Student Aid Web sites, such as FAFSA on the Web.
Parents who wish to electronically sign their child's FAFSA also need to
obtain a PIN.

A PIN that is selected or viewed instantly online, or is sent to the
applicant in an e-mail, is considered to be conditional until the
applicant's information is verified with the Social Security
Administration (1-3 days from the date of application). Applicants may
sign their FAFSA using the PIN, but nothing else. Once the Department
completes the verification with SSA, applicants are able to use their
PIN for other purposes, such as correcting their SAR or accessing other
Federal Student Aid Web sites. Individuals that wish to receive a
conditional PIN prior to accessing FAFSA on the Web, may request one at
www.pin.ed.gov.

***Other Changes Mandated by the College Cost Reduction and Access Act
of 2007***

In response to the College Cost Reduction and Access Act (CCRAA) of
2007, the Department will remove certain questions from, and add new
questions to, the 2009-2010 FAFSA. (For a complete description, see the
'Data Elements Justification' document, attached)

The most significant changes include the expansion of the dependency
criteria (Step Three of the FAFSA) to designate individuals who were in
foster care (age 13 or older); emancipated minors or minors in legal
guardianship; and individuals that have been verified as an
unaccompanied youth who are homeless children or youth or are at risk of
homelessness, as independent students for FAFSA/Title IV, HEA program
assistance purposes. Other changes include adding 'dislocated worker' to
the list of criteria that could qualify an applicant for the Simplified
Needs Test (SNT) and or Automatic Zero EFC (Auto Zero); adding the TEACH
Grant question to the paper FAFSA; increasing the time period for
measuring Federal means-tested benefits (Steps Four & Five of the FAFSA)
from 12 months to 24 months; the deletion of Worksheet A from the FAFSA;
and the deletion of two questions from Worksheet B (foreign income
exclusion, and credit for federal tax on special fuels). As a result of
the CCRAA, all worksheets have been deleted. Information formerly
aggregated on Worksheets B and C is now collected on the form in
sections labeled 'Additional Financial Information' (formerly Worksheet
C) and 'Untaxed Income and Benefits' (formerly Worksheet B).

As in years past, the Department has convened a FAFSA Design Group to
determine how the changes can be implemented with minimal disruption to
the application process and without adding undue burden or confusion for
our applicants. The changes will be implemented across the suite of
FAFSA products. We look forward to receiving public comment on the
proposed changes mandated by the CCRAA during the public comment period.

Security of applicant data on the Internet continues to be an issue of
great concern. FAFSA on the Web uses the commercial encryption protocols
available in the most commonly used Internet browsers. Initially, the
Department required the strongest encryption levels available
commercially (128-bit encryption). As requested by the Office of
Management and Budget (OMB), since March 8, 1998, the Department also
gives applicants a choice to use both 40-bit and 56-bit encryption as
well. This step has greatly improved customer access to FAFSA on the Web
and Renewal FAFSA on the Web while still retaining necessary security
safeguards for student and parent information. In compliance with the
Americans with Disabilities Act, FAFSA on the Web will continue to be
accessible to visually impaired applicants for the 2008-2009 award year
cycle. Applicants who complete the paper FAFSA must provide a written
signature.

The Department continues to be committed to providing electronic
applications. All methods of electronic application share the following
benefits:

1)  Faster processing than paper FAFSAs;

2)  Reduced rate of rejection. (Approximately 8% for all paper FAFSAs
    and 0.5% for electronic FAFSAs. These percentages exclude signature
    rejects.);

3)  Internal and end-of-entry edits to ensure that all required fields
    are completed and all conflicting data are resolved prior to
    submission. (Contributes to reduced rejection rate, above);

4)  Skip logic, which helps shorten FAFSA on the Web by allowing
    applicants to skip questions that do not pertain to them;

5)  FAFSA on the Web pre-fills certain questions based on earlier
    answers; and

6)  Availability of on-line help.

***FAA Access to CPS Online***

Since 2002, Financial Aid Administrators (FAA's) at participating Title
IV postsecondary educational institutions have had the ability to input
and transmit a student's original or pre-filled FAFSA data over the
Internet via FAA Access to CPS Online. Providing this tool to FAA's
greatly increases the likelihood that prospective college students from
traditionally underrepresented or economically disadvantaged groups will
complete the financial aid application process electronically.

***FAFSA4caster***

In addition to helping families make informed decisions as they plan for
college well in advance of the student's senior year in high school, the
FAFSA4caster also reduces the application time when students file a
FAFSA in their senior year in high school. The FAFSA4caster pre-fills
certain data that the applicant needs to adjust only if the information
has changed since the previous FAFSA4caster submission. This
significantly reduces the time it takes for the student to complete the
FAFSA in their senior year of high school. FAFSA4caster instantly
calculates an estimate of the student\'s eligibility for federal student
aid, including grants; reduces the time it will take to complete the
Free Application for Federal Student Aid (FAFSA); and simplifies the
financial aid process for students and families.

**4. Describe efforts to identify duplication. Show specifically why any
similar information already available cannot be used or modified for use
of the purposes described in Item 2 above.**

The collection requirements for the FAFSA do not contain any duplication
of data elements. The Pre-filled FAFSA contains the same questions as
the FAFSA, but the Pre-filled FAFSA is filed in place of, not in
addition to, an original FAFSA. The Pre-filled FAFSA does not require
responses to items that were reported previously and do not need
updating. Required responses are limited to income and asset questions
that are likely to change from year to year.

The SAR collects some corrected information that duplicates information
collected by the FAFSA. However, the SAR is the output document
containing data that are derived from the application and does not
duplicate the process of initial data collection.

**5. If the collection of information impacts small businesses or other
small entities (Item 5 of OMB Form 83-I), describe any methods used to
minimize burden.**

Title IV participating postsecondary educational institutions may
contract with small businesses as third-party servicers to perform work
normally completed by the institution. The tasks the third-party
servicer would complete with regard to the completion and submission of
FAFSA data mirrors the process that the institution would follow,
therefore, burden is minimized to the extent that these changes have
brought about a reduction in burden to the user, whether it is the
institution or the institution's contracted third-party servicer.
Otherwise, the FAFSA is not used by small businesses or other small
entities.

 

**6. Describe the consequences to federal program or policy activities
if the collection is not conducted or is conducted less frequently, as
well as any technical or legal obstacles to reducing burden.**

Within the HEA, the Secretary is mandated to determine a student\'s need
for financial aid on an annual basis. If the data were collected less
frequently, the Department would be in violation of the law. Although a
student must reapply and receive a new need analysis for every year that
financial aid is requested, use of the Pre-filled FAFSA reduces the
amount of new data that a student must provide.

**7. Explain any special circumstance impacting the information
collection.**

The 2009-2010 FAFSA does not collect information in a manner that would
invoke special circumstances, as described in the Paperwork Reduction
Act submission instructions.

 

**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 1320.8(d), soliciting comments on the information collection
prior to submission to OMB**.

A Notice opening the 60-day public comment period was posted in the
Federal Register on August 28, 2008 (Volume 73, No. 168, Page 50785). As
a result of this Notice, the Department received more than 100 public
comments. Two separate documents (attached) provide information about
each comment and the Department's disposition on each.

A second Notice opening a 30-day public comment period was posted in the
Federal Register on November 3, 2008 (Volume 73, Number 213, Page
65298).

In addition to soliciting feedback from the public via the formal
Notices, again this year the Department established a 'FAFSA workgroup'
for the 2009-2010 FAFSA which included representatives from National
Association of State Student Grant and Aid Programs (NASSGAP), National
Association of Student Financial Aid Administrators (NASFAA), Federal
Student Aid, the Department, and Title IV participating postsecondary
educational institutions. Department staff also actively solicited
comments on the draft 2009-2010 FAFSA at conferences, including Federal
Student Aid's two national conferences, the NASFAA conference, and
through smaller venues such as college fairs and community
presentations.

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

Individuals who choose to complete the 2009-2010 FAFSA are applying for
federal benefits. They do not receive payments or gifts for the
completion and submission of the FAFSA.

 

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

The confidentiality of the data collected by the 2009-2010 FAFSA is
discussed in the Routine Uses section of the System of Records Notice
for the Federal Student Aid Application File published on page 30159 of
the Federal Register dated June 4, 1999 and updated on page 72407 on
December 27, 1999; page 11294 on March 2, 2000; and on page 18758 on
April 11, 2001. A section on Privacy, printed on Page 8 of the
application package, informs the student that the postsecondary
educational institutions and state agencies to which the student
requests his or her data be sent will have access to the data, and that
the financial aid agency(ies) in his or her state of legal residence
will receive certain information, even if the student does not consent.
In addition, agencies such as law enforcement agencies, OMB, the
Department of Justice, the Government Accountability Office, Congress,
and entities such as the Inspector General\'s office have access to the
data.

 

**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.**

Except for question 23 (have you been convicted for the possession or
sale of illegal drugs for an offense that occurred while you were
receiving federal student aid) and questions 24 and 25 (what is your
parents' level of education), the FAFSA does not contain questions of a
sensitive nature beyond those needed to obtain the information necessary
to determine an EFC.

Question 23 is used to determine a student's eligibility for Title IV
assistance in accordance with section 484(r) of the HEA. Questions 24
and 25 are used by some state grant and scholarship programs, some
institutions, and the TRIO programs, which give special consideration to
first‑generation college students. The FAFSA instructions inform
applicants that their responses to questions 24 and 25 do not affect
their eligibility for federal student assistance.

 

**12. Provide estimates of the hour burden of the collection of
information.**

The number of responses for the 2009-2010 FAFSA is estimated on the
basis of one response per FAFSA submitted. The total applicant
population comprises significant cohorts of individuals who, by statute,
are required to complete only certain segments of the FAFSA. The HEA
mandates certain data elements for specific populations. The following
estimate takes into consideration the burden hour calculations for each
unique applicant subpopulation (e.g., dependent vs. independent
students) and the type of application (Web or paper) filed by each
applicant.

+-------------------------------+----------+--------+--------+-------+
|                               | **Type   | **Est  | **Est  | *     |
|                               | of FAFSA | imated | imated | *Esti |
|                               | Resp     | Number | Hours  | mated |
|                               | ondent** | of     | to     | Total |
|                               | (Ind     | FAFSA  | Co     | B     |
|                               | ependent | R      | mplete | urden |
|                               | or       | espond | F      | Ho    |
|                               | De       | ents** | AFSA** | urs** |
|                               | pendent) |        | (Pe    |       |
|                               |          | (V     | rcent) |       |
|                               |          | olume) |        |       |
+-------------------------------+----------+--------+--------+-------+
| ######### FAFSA Paper Form    | D        | 92,466 | .97    | 8     |
|                               | ependent |        |        | 9,692 |
| *(Traditional paper FAFSA     | *54%*    |        |        |       |
| that is printed by the        |          |        |        |       |
| government and distributed    |          |        |        |       |
| nationally to schools,        |          |        |        |       |
| libraries, etc.)*             |          |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | Ind      | 78,768 | .87    | 6     |
|                               | ependent |        |        | 8,528 |
|                               | *46%*    |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | S        | *      |        | ***   |
|                               | ubtotals | **171, |        | 158,2 |
|                               |          | 234*** |        | 20*** |
|                               |          |        |        |       |
|                               |          | **     |        |       |
|                               |          | *1%*** |        |       |
+-------------------------------+----------+--------+--------+-------+
| ######### FAFSA on the Web    | D        | 4,4    | .62    | 2,75  |
|                               | ependent | 38,383 |        | 1,797 |
| *(Web-based version of the    | *54%*    |        |        |       |
| FAFSA that is available via   |          |        |        |       |
| the Internet.)*               |          |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | Ind      | 3,7    | .42    | 1,58  |
|                               | ependent | 80,845 |        | 7,955 |
|                               | *46%*    |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | S        | ***    |        | ***4, |
|                               | ubtotals | 8,219, |        | 339,7 |
|                               |          | 228*** |        | 52*** |
|                               |          |        |        |       |
|                               |          | ***    |        |       |
|                               |          | 48%*** |        |       |
+-------------------------------+----------+--------+--------+-------+
| ######### FAFSA Electronic    | D        | 3      | .82    | 29    |
|  (Also known as 'FAA Access') | ependent | 59,591 |        | 4,865 |
|                               | *30%*    |        |        |       |
| *(Electronic version of the   |          |        |        |       |
| FAFSA that can be used by     |          |        |        |       |
| Financial Aid Administrators, |          |        |        |       |
| third-party servicers, etc.)* |          |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | Ind      | 8      | .69    | 57    |
|                               | ependent | 39,046 |        | 8,942 |
|                               | *70%*    |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | S        | ***    |        | ***   |
|                               | ubtotals | 1,198, |        | 873,8 |
|                               |          | 637*** |        | 07*** |
|                               |          |        |        |       |
|                               |          | **     |        |       |
|                               |          | *7%*** |        |       |
+-------------------------------+----------+--------+--------+-------+
| ######### FAFSA EZ            | D        | 1      | .20    | 2     |
|                               | ependent | 19,864 |        | 3,973 |
| *(FAFSA on the Web is         | *35%*    |        |        |       |
| front-loaded with questions   |          |        |        |       |
| that identify certain         |          |        |        |       |
| applicants as being eligible  |          |        |        |       |
| for an "automatic zero EFC."  |          |        |        |       |
| This reduces the information  |          |        |        |       |
| collection burden for those   |          |        |        |       |
| applicants who are most in    |          |        |        |       |
| need of financial aid.)*      |          |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | Ind      | 2      | .20    | 4     |
|                               | ependent | 22,604 |        | 4,521 |
|                               | *65%*    |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | S        | *      |        | **    |
|                               | ubtotals | **342, |        | *68,4 |
|                               |          | 468*** |        | 94*** |
|                               |          |        |        |       |
|                               |          | **     |        |       |
|                               |          | *2%*** |        |       |
+-------------------------------+----------+--------+--------+-------+
| ########                      | D        | 3,0    | .42    | 1,29  |
| # Pre-Filled FAFSA on the Web | ependent | 71,937 |        | 0,214 |
|                               | *46%*    |        |        |       |
| *(The Pre-Filled FAFSA        |          |        |        |       |
| contains certain constant,    |          |        |        |       |
| preprinted data and an        |          |        |        |       |
| applicant need only update    |          |        |        |       |
| those data elements that have |          |        |        |       |
| changed from the prior year.  |          |        |        |       |
| Data elements contained on    |          |        |        |       |
| the Renewal FAFSA are         |          |        |        |       |
| identical to those on the     |          |        |        |       |
| FAFSA, but fewer responses    |          |        |        |       |
| are required of applicants.)* |          |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | Ind      | 3,6    | .39    | 1,40  |
|                               | ependent | 06,186 |        | 6,413 |
|                               | *54%*    |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | S        | ***    |        | ***2, |
|                               | ubtotals | 6,678, |        | 696,6 |
|                               |          | 123*** |        | 27*** |
|                               |          |        |        |       |
|                               |          | ***    |        |       |
|                               |          | 39%*** |        |       |
+-------------------------------+----------+--------+--------+-------+
| ########                      | D        | 1      | .42    | 6     |
| # Pre-Filled FAFSA Electronic | ependent | 54,111 |        | 4,727 |
|                               | *30%*    |        |        |       |
| *(Electronic version of the   |          |        |        |       |
| Pre-Filled FAFSA that can be  |          |        |        |       |
| used by financial aid         |          |        |        |       |
| administrators, third-party   |          |        |        |       |
| servicers, etc.)*             |          |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | Ind      | 3      | .39    | 14    |
|                               | ependent | 59,591 |        | 0,240 |
|                               | *70%*    |        |        |       |
+-------------------------------+----------+--------+--------+-------+
|                               | S        | *      |        | ***   |
|                               | ubtotals | **513, |        | 204,9 |
|                               |          | 702*** |        | 67*** |
|                               |          |        |        |       |
|                               |          | **     |        |       |
|                               |          | *3%*** |        |       |
+-------------------------------+----------+--------+--------+-------+
| ***Total***                   |          | **     |        | ***8, |
|                               |          | 17,123 |        | 341,8 |
|                               |          | ,392** |        | 67*** |
+-------------------------------+----------+--------+--------+-------+

**Application volume projections:**

2006. 13,852,804 (actual volume as of 8/6/06 -- projected to increase
      slightly prior to CPS close-out)

2006-2007 14,867,558

2007-2008 15,952,890

2008-2009 16,787,640

2009-2010 17,123.392 (based upon 2% increase from 2008-2009)

**13. Provide an estimate of the total annual cost burden to respondents
or record keepers resulting from the collection of information.**

There is no annual cost burden to respondents or record keepers.

**14. Provide estimates of annualized cost to the federal government.**

** **

Below are the estimated costs to the federal government to produce,
process, and distribute the 2009-2010 FAFSA, FAFSA on the Web, Renewal
FAFSA on the Web, and the electronic versions of these applications,
including the CPS system.

## A. CPS Projected Costs at the Virtual Data Center

# 

# FY 2007 (includes parts of the 2006-2007 and 2007-2008 award year processing cycles.)

# 

+-------------+--------------------------------------------------------+
| # \         | # Includes mainframe proce                             |
| $18,956,011 | ssing; software; system security and protection; capac |
|             | ity; storage (tape backup and optical); printing; etc. |
+-------------+--------------------------------------------------------+

# 

## Data Entry, System Development, Data Processing

The CPS is responsible for a category called Data Entry or Image and
Data Capture (IDC) - delivery of data entry services resulting from the
paper FAFSA and other related forms transmitted through a reliable and
secure data capture system. Processing operations will include the
receipt of FAFSA forms and the timely imaging, data capture and
transmission of data and images for processing:

FY 2008 total data entry cost \$7,622,645

FY 2008-09 processing cycle \$5,536,204

FY 2008-09 development cycle ........\$12,508,165

### B. Other Costs

  --------------------------------------------- -------------------------
  FAFSAs (paper)                                

  Printing                                      \$2,527,153

  Distribution/Postage                          \$1,335,028

  FAFSA related customer responses              

  Telephones                                    \$20,822,647

  Correspondence                                \$890,000

  FAFSA Design Group                            

  Contractor Support/Usability Testing          \$60,000

  SUBTOTAL                                      \$25,634,828
  --------------------------------------------- -------------------------

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

The Department projects that there will be a 3 percent increase in the
total number of FAFSA submissions during the 2009-2010 FAFSA processing
cycle. This growth is due to the weakening national economy (individuals
historically return to school during economic downturns) and a growth in
the college age population in the U.S. from the previous year. The total
burden hour will increase by 37,520 hours and is reflected in this
submission as an 'Adjustment'.

**16. For collections of information whose results will be published,
outline plans for tabulation and publication. Address any complex
analytical techniques that will be used.**

The results of the collected information will not be published for
tabulation or publication.

 

**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 expiration date for OMB approval will not be included on the
2009-2010 FAFSA for design reasons, although the OMB control number is
displayed. The term of approval and use of the form is apparent in the
first-page instructions that inform applicants to send in the form
between January 1, 2009 and June 30, 2010.

 

**18. Explain each exception to the certification statement identified
in Item 20, \"Certification for Paperwork Reduction Act Submissions,\"
of OMB Form 83-I.**

Exceptions to the certification requirement are not requested for this
information collection.