**SUPPORTING STATEMENT FOR REQUESTS FROM OMB FOR APPROVAL**

**UNDER THE PAPERWORK REDUCTION ACT OF 1995 AND 5 CFR 1320**

**2009-2010 FISAP and 2008 Reallocation**

SUPPORTING STATEMENT FOR REQUESTS FROM OMB FOR APPROVAL

UNDER THE PAPERWORK REDUCTION ACT AND 5 CFR 1320

A. Justification

**1.** **Explain the circumstances that make the collection of
information necessary. Identify any legal or administrative requirements
that necessitate the collection. Attach a copy of the appropriate
section of each statute and regulation mandating or authorizing the
collection of information.**

##### 

#####  FISAP

The Higher Education Act of 1965, as amended, requires an institution to
apply for participation and report the expenditures for the Federal
Perkins Loan, the Federal Supplemental Educational Opportunity Grant
(FSEOG) and the Federal Work-Study (FWS) Programs on an annual basis.
The data submitted electronically in the 2008-2009 Fiscal Operations
Report and 2009-2010 Application to Participate (FISAP) is by the
Department of Education (ED or the Department) to determine the
institution\'s funding need for the Award Year and monitor program
effectiveness and accountability of fund expenditures. The data will be
used in conjunction with institutional program reviews to assess the
administrative capability and compliance of the applicant. There are no
other sources for collecting this data. Sections of the Higher Education
Act of 1965, as amended that govern these programs can be found at
<http://edworkforce.house.gov/publications/heacomp/hea65003.pdf>

The legislative authority governing the application for the distribution
of Federal Perkins Loan funds is 20 U.S.C. 1087bb (34 CFR 673.3); for
FWS funds it is 42 U.S.C. 2752 (34 CFR 673.3); and for FSEOG funds it is
20 U.S.C. 1070b-3 (34 CFR 673.3).

The legislative authority governing the annual report on the use made of
funds provided under the previous sections is (20 U.S.C. 1094) enacted
October 3, 1980, P.L. 96-374, sec. 451(a), 94 Stat. 1451; amended April
7, 1986, P.L. 99-272, sec. 16034, 100 Stat. 356; amended October 17,
1986, P.L. 99-498, sec. 487(a), 100 Stat. 1486.

######  Reallocation Form

The Higher Education Act of 1965, as amended, (HEA) requires that if an
institution anticipates not using all of its allocated funds for the
Federal Perkins Loan, Federal Work Study (FWS), and/or Federal
Supplemental Educational Opportunity Grant (FSEOG) programs by the end
of an award year, it must specify the anticipated remaining unused
amount to the Secretary, who reduces the institution's allocation
accordingly. The specifying of unused amounts would be done in Section A
of this form.

The HEA also requires the Secretary to reallocate these unexpended funds
before the appropriations expire on September 30, immediately following
their release in this form. The data collected in Section B will provide
the minimum information needed by the Secretary to determine a fair and
equitable distribution of supplemental FWS allocations for the purpose
of furthering the program's community service goals.

The legislative authority governing the reallocation of Federal Perkins
Loan funds is 20 U.S.C. 1087bb (34 CFR 673.3); for FWS funds it is 42
U.S.C. 2752 (34 CFR 673.3); and for FSEOG funds it is 20 U.S.C. 1070b-3
(34 CFR 673.3).

Section 462(i), 442(d), and 413D(d), gives the Secretary the authority
to reallocate to other institutions any funds returned to the Secretary
by institutions with an excess in any of their allocations.

ED is requesting the review and continued approval for the requirements
contained in 34 CFR 673.3, 674.19, 675.19, and 676.19.

**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.**

#####  FISAP

The relative institutional financial need, which is the basis for
computing by formula the amount of funds needed by each institution to
operate one or more of the campus-based programs during the application
year, is determined by the data reported in this submission. The data is
used to assess program effectiveness and accountability of fund
expenditures under the previously cited authority. In addition, the data
is used along with institutional program reviews to help assess the
administrative capability of the applicant and enforce compliance.

a)  Application data will allow a standard measure of institutional need
    culminating in a level of funds for institutions requesting
    participation in one or more of the programs.

b)  Application data will allow for maintaining a database sufficiently
    comprehensive and reliable to calculate yearly funding formulas
    based on verifiable data input.

c)  Expenditure data will be used to calculate past utilization of funds
    awarded for our assessment of penalties, recovery of unexpended
    funds, and close-out of awards.

d)  Data regarding Perkins Loan collection activities will be used for
    computation of institutional default rates; the compilation of the
    Federal Perkins Loan Status of Default (orange book); and issuance
    of the teaching, military, volunteer, law enforcement and
    corrections officer, child, family, & early intervention, and nurse
    and medical technician services cancellation payments, as well as
    cancellation payments for surviving spouses of public service
    victims of the 9/11 terrorist attacks.

e)  Data is maintained and made readily available to Departmental staff
    and other agencies for analysis, historical research, budget
    evaluations, audits, program reviews, and Office of Inspector
    General (OIG) inquiries.

f)  The Campus-Based System processes all FISAP on the web information
    in a real-time format into the database. Institutions with
    outstanding compliance signature forms are automatically placed on a
    file to withhold funding until the forms have been received and
    validated.

g)  The data collected will be used for the identification of poorly
    administered operations that may require on-site monitoring,
    additional training of institutional personnel, or termination of
    funding in extreme cases.

ED would be unable to comply with authorizing legislation and
appropriation legislation without the information collected in this
submission.

######  Reallocation Form

The unused or unspent funds reported in Section A will be distributed by
the Department as supplemental awards to qualifying institutions in
accordance with provisions of the Higher Education Act. FWS funds will
be awarded to eligible institutions that used at least 5 percent of the
total FWS funds to compensate students employed as reading tutors of
children or in family literacy activities as part of their
community-service activities. Because FWS reallocated funds will be
distributed on the basis of fair share, institutions must have a fair
share shortfall to receive these funds. Institutions use the reallocated
funds to compensate students employed in community service. If the
unused funds are not reported, they cannot be redistributed for use
under the campus-based programs, as required by the legislation.

> Failure to collect this information would prevent maximum utilization
> of the appropriated funds, deprive needy students of financial aid,
> and result in our non-compliance with the reallocation provisions of
> the HEA.

ED would be unable to comply with authorizing legislation and
appropriation legislation without the information collected in this
submission.

3.  **Describe whether, and to what extent, the collection of
    information involves the use of automated, electronic, mechanical,
    or other technological collection techniques or other forms of
    information technology, e.g. permitting electronic submission of
    responses, and the basis for the decision for adopting this means of
    collection. Also describe any consideration of using information
    technology to reduce burden.**

######  FISAP

For the 2009-2010 award year, institutions will continue to use the
Department\'s electronic services to participate in the Title IV
Programs. In order to submit information, all institutions requesting
participation in the campus-based programs must submit FISAP data
through e-Campus-Based FISAP on the web at:
[http://cbfisap.ed.gov](http://cbfisap.ed.gov/).

-   Institutions will print out the certification signature page
    directly from their computers for signature.

-   FSA plans to implement an e-authentication process in the near
    future, which should alleviate the need for institutions to submit
    hard copy forms with signatures.

> [Reallocation Form]{.underline}
>
> This form is now being transmitted to and received from campus-based
> institutions using the e-Campus-Based FISAP on the web. This procedure
> has eliminated printing costs, distribution expense, data entry time,
> and reduced the cycle time and completion mistakes. This process
> reduces institutional burden by using three years of information
> already contained in the Department's database to provide
> institutional characteristics to verify funding levels and reduce the
> number of staff necessary to process the information.

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

#####  FISAP

No other agency collects the information needed to determine the
allocation of campus-based aid. It was previously anticipated that small
amounts of Federal Perkins Loan data could be retrieved from the
National Student Loan Data System (NSLDS). However, as currently
designed, the NSLDS does [not]{.underline} and can [not]{.underline}
collect data that would sufficiently correspond to the type of data
required from the FISAP for such items as award calculations, cohort
default rate calculations, cumulative collections data, prior year
account reconciliation data, etc.

There is also no statutory requirement for NSLDS to collect Perkins
interest data. NSLDS does not collect any FSEOG disbursement data, only
FSEOG overpayments. There is [no]{.underline} data collected for the FWS
Program in NSLDS. There remain a number of operational issues (such as
the timing of the submission of NSLDS Federal Perkins Loan Program data
to the Department and the manner in which it is collected) that will
limit its use as a substitute for FISAP reporting.

Section A of the Perkins Loan Report (FISAP, Part III) contains 60 cells
of data and Section C contains 30 data cells. NSLDS does not contain
sufficient historical information to populate the cells in these two
sections that require data to be cumulative from the beginning of an
institution's participation. Section B of the Perkins Loan Report has 13
data cells. Two cells, loans advanced to students during the Report year
and principal and interest repaid by borrowers for the same year, could
conceivably be populated with data from NSLDS. Sections D and E contain
cohort default rate data, which might also be available from NSLDS at
some point in the future.

Summary: There are plans to address the interest issue when NSLDS is
redesigned. In addition, NSLDS will be comparing the definitions used in
both NSLDS and the FISAP to gain greater consistency. However, our
review of the data needed for completion of the five sections of the
Perkins Loan Report and the data available in NSLDS leads us to conclude
that NSLDS data will not currently provide data that will be compatible
with either the historical or annual data being collected on the FISAP.
At this time, institutions will continue to be required to provide FISAP
data in order for the Department to carry out required functions such as
the calculation of allocations and cancellation reimbursements that use
this information.

######  Reallocation Form

> Similar information is not available at the time it is needed. The
> Department must rely on this information being reported by
> institutions at the end of each June 30^th^ award period. The
> reporting and redistribution must be complete prior to September
> 30^th^, or the authority to obligate these funds will expire.

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

#####  FISAP

The collection of this information does not involve small businesses or
other small entities. Information is collected from Title IV eligible
schools only.

######  Reallocation Form

This collection does not involve 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.**

#####  FISAP

The Department would be unable to comply with authorizing legislation
and appropriation legislation that requires annual distribution of
appropriated funds on the basis of an annual application from colleges
and universities.

#####  Reallocation Form

> If the collection were done less frequently, the authority to
> redistribute the excess funds would expire on September 30^th^, and
> there would be no reallocation of funds as legislatively required.

**7.** **Explain any special circumstances that the collection to be
conducted was done in a manner inconsistent with the guidelines in 5 CFR
1320.5.**

#####  FISAP

There are no special circumstances inconsistent with the guidelines.

#####  Reallocation Form

There are no special circumstances inconsistent with the guidelines.

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

#####  FISAP

Campus-based staff members in both operations and policy areas provide
presentations and support for a number of national and regional
conferences. During these activities, staff members take all comments,
recommendations, and suggestions made by institutions for use in
determining the need for improvement or change to existing policies and
procedures.

Frequent communication with institutions by our Call Center and
campus-based staff provides additional information on the data being
collected and on problems with electronic processing requirements.
Comments from schools are shared with staff members and frequently
included as possible upgrades to existing procedures. Institutions
continue to favorably respond about the ease in completing and
submitting the data on-line.

The Department's OMB clearance process allows further opportunity for
comment on the FISAP through an announcement in the Federal Register at
the onset of the clearance process. ED accepts public comments on the
FISAP during this 60-day time period. Historically institutions rarely
make comments on the FISAP. The campus-based programs have been in
operation for more than 40 years, and completion of the annual FISAP is
a common practice for institutions.

#####  Reallocation Form

The reporting of unused or unspent funds by institutions participating
in the campus-based programs is a requirement of the Higher Education
Act of 1965, as amended. Institutions submit part of this information
annually in the FISAP, at a later date. The collection of this data is
frequently discussed at financial aid conferences, and the financial aid
community provides unsolicited comments through their contacts with our
Call Center and campus-based staff members.

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

#####  FISAP

Participants receive only those funds that have been calculated for them
according to previously cited statutes in the Higher Education Act of
1965, as amended.

######  Reallocation Form

There is no payment of gift to respondents other than the allocation of
Federal funds that result from the information collected.

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

#####  FISAP

FISAP data is public information.

#####  Reallocation Form

This is public information.

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.**

#####  FISAP

No questions of a sensitive nature are asked.

> [Reallocation Form]{.underline}

This collection does not include information of a sensitive nature.

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

######  FISAP 

The data collection is composed of six parts. Parts I and II are the
application, Part III is the Federal Perkins Loan Report, Part IV is the
FSEOG Report, Part V is the FWS Report and Part VI is the Program
Summary. The range of time required to complete the various parts of the
form depends on several variables: (1) the number of programs in which
respondents are currently participating; (2) whether the respondent is a
\"first-time\" or \"continuing\" applicant; and (3) the type of
institution.

We estimate a total of 4,048 respondents, approximately 100 being
\"first-time\" applicants, with an estimated average response time of
6.86 hours and a total of 27,774 hours for all institutions. Burden
hours for new schools are minimal since they are only required to
complete the first two Parts (Identifying Information, Certifications
and Warning and the Application to Participate).

The following matrix will show the respondent participation in the
various parts of the submission. The total amounts shown by
institutional type are unduplicated counts. The part breakdowns under
each category of institution are duplicated counts, based on the
variables mentioned above.

Proprietary institutions use less time to prepare the FISAP than public
and private institutions. A recent random sampling of institutions
revealed that proprietary institutions were more likely to use servicers
to prepare their FISAP. Since servicers prepare FISAPS in volume, they
tend to keep their computerized data systems updated, and have totally
encompassed ED\'s electronic processes into their systems which results
in less FISAP preparation time.

Most public and private institutions have restructured their data
collection processes so that information is readily accessible to
complete the eCampus-Based FISAP on the web. Identifying information is
pre-populated on the FISAP from prior year data and common mathematical
computations are automatically displayed, which reduces the
institutional burden.

Est. of Avg.

##  Respondent Type Estimated Person Hours Total

[By Part]{.underline} [Number]{.underline} [Per Respondent]{.underline}
[Hours]{.underline}

[Proprietary]{.underline}

Application 916 1.65 1,511.40

Federal Perkins Loan 494 1.34 661.96

FSEOG 955 1.05 1,002.24

FWS 426 .55 233.68

Summary [982]{.underline} .41 [400.25]{.underline}

**Total Proprietary**

**Schools** **[1,106]{.underline} [3,809.53]{.underline}**

[Public]{.underline}

Application 1,395 2.88 4,017.60

Federal Perkins Loan 928 2.58 2,394.24

FSEOG 1,465 1.60 2,343.84

FWS 1,481 2.09 3,087.46

Summary [1,500]{.underline} 1.48 [2,220.55]{.underline}

**Total Public**

**Schools: [1,497]{.underline} [14,063.69]{.underline}**

[Private]{.underline}

#  Application 1,328 2.45 3,253.60

Federal Perkins Loan 1,130 2.15 2,429.50

FSEOG 1,320 1.01 1,331.49

FWS 1,375 1.19 1,630.19

Summary [1,417]{.underline} .89 [1,255.95]{.underline}

**Total Private**

**Schools: [1,445]{.underline} [9,900.73]{.underline}**

**Grand Total: [4,048]{.underline} 6.86 [27,773.95]{.underline}**

[Reallocation Form]{.underline}

This form is composed of two sections. Section A requests unexpended
allocation figures for the three campus-based programs. Section B
requests information regarding supplemental FWS funds. The range of time
required to complete the two sections of the form depends on several
variables: (1) the number of programs in which respondents are currently
participating; and (2) whether or not an institution requires
supplemental Federal funds for community service activities.

The following matrix will show the respondent participation in the
various sections of the form. The total amounts shown are unduplicated
counts. The section breakdowns under Estimated Number and Estimated
Average of Person Hours Per Respondent are duplicated counts, based on
the variables mentioned above.

Est.of Avg.

##  Respondent Type Estimated Person Hours Total

[By Section]{.underline} [Number]{.underline} [Per
Respondent]{.underline} [Hours]{.underline}

[Section A]{.underline}

Proprietary 187.50 00.15 28.13

Public 412.50 00.15 61.87

Private [150.00]{.underline} [00.15]{.underline} [22.50]{.underline}

**Total Section A [750.00]{.underline} [00.15]{.underline}
[112.50]{.underline}**

[Section B]{.underline}

Proprietary 250.00 00.05 12.50

Public 550.00 00.05 27.50

Private [200.00]{.underline} [00.05]{.underline} [10.00]{.underline}

**Total Section B** **[1,000.00]{.underline} [00.05]{.underline}
[50.00]{.underline}**

**Grand Total:** **[1,750.00]{.underline}** **[00.20]{.underline}**
**[162.50]{.underline}**

#####  

#####  Total for FISAP and Reallocation Form 

The combined total for the FISAP and Reallocation form has an estimated
total of 5,798 respondents, with an estimated response time of 4.82
hours for a total of 27,936 hours for all institutions. The estimated
total cost to respondents would be \$558,720.00.

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

######  FISAP

The nature of business for educational institutions (ED\'s respondents)
is such that purchases of equipment and provision of services that are
required for electronic FISAP processing are a part of their customary
and usual business practice. They are the type of equipment and services
normally necessary to successfully operate any educational entity.

The requirement to transmit FISAP data through eCampus-Based FISAP on
the web is not considered an increase in burden for most institutions.
Since thousands of institutions are already participating in other Title
IV programs, they would have access to the Internet (web) in order to do
business with the Department.

######  Reallocation Form

The nature of business for educational institutions (ED\'s respondents)
is such that purchases of equipment and provision of services that are
required for electronic FISAP processing are a part of their customary
and usual business practice. They are the type of equipment and services
normally necessary to successfully operate any educational entity.
Therefore, no special equipment or services are required for completing
the Reallocation Form.

**14.** **Provide estimates of annualized cost to the Federal
Government.**

#####  FISAP

[Cost for Development of eCampus-Based FISAP on the Web]{.underline}

Many tasks must be performed in order to develop the FISAP on the Web
and make it available to campus-based participants. Some of the major
costs include the costs for contractor services, the development of web
server programs, the Technical Reference, documents for posting on the
web (i.e. Dear Partner Letters), and the FISAP Form and Instructions
Booklet. The amount below reflects all of these campus-based programs
cost to the Department.

Total\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....................................\...\...\...\...\...\...\....
\$458,220

(The FISAP on the Web cost is replacing the old Publication &
Distribution Cost calculation because it is no longer needed)

[Operation & Maintenance Costs to the Federal Government]{.underline}

Monthly Data Collection &
Maintenance\...\.................\...\.......................\$88,750

2020, LLC

> 3110 Fairview Park Drive
>
> Suite 950

Falls Church, VA 22042

Total Yearly Cost (12 months-1
month).........\............................\...\.... \$976,250

The cost of collecting and maintaining the data is justified because
FISAP data is made available to, and widely used, throughout the
Department for analysis, historical research, budget evaluations,
audits, program reviews, OIG inquiries, etc. In addition, the
information collected justifies institutional funding for the next award
period.

[Staffing, Operations, & Overhead Costs]{.underline}

A staff of 12 is required for the effective and complete operation of
the campus-based programs. As the driving force in these operations, the
FISAP is the instrument by which institutions request campus-based
funding and report program expenditures. The FISAP provides the data
that is required to perform a variety of processes such as funding
calculations, program compliance, analysis, customer service,
information publication and distribution, accounting and fund control,
etc. The types of program staff include managers, accountants, financial
management specialists, technicians, systems analysts, and clerical
staff.

Yearly staff
costs\...\...\...\...\...\...\...\........................................................\$977,129

The 12 employees worked 2,087 hours per year for a total 25,044 hours
worked for the office. The average cost per hour was calculated by using
the \$989,216 total salaries divided by 25,044 total hours worked for an
average cost per hour of \$39.50. All but approximately one month is
spent working on FISAP related tasks. The remaining time is spent
working on Reallocation Form tasks, so \$12,087 was deducted from the
total cost (102 hours X 3 employees X \$39.50 average hourly rate).

Yearly overhead
costs\...\...\...\.............................................\...\...\......\...\$156,341

A standard budget estimate of 16% was used to determine the overhead
costs of staff operations including such items as equipment, utilities,
work materials, etc.

Total staff and overhead
costs\...\...\...........................................\......\$1,113,470

[Reallocation Form]{.underline}

[Publication and Distribution]{.underline}

Publication and distribution cost to the campus-based programs has been
eliminated. The conversion to the eCampus-Based FISAP on the web has
transferred all costs, including software production and distribution,
into the overall contract for services made by the Department.

Total\...\...\...\...\...\...\...\...\.......................\...\...\...\...\...\............\...\...\...................\...\.....
\$0

[Operation & Maintenance Costs to the Federal Government]{.underline}

Monthly Collection & Maintenance for 2 half
months..........................\$88,750

2020, LLC

> 3110 Fairview Park Drive
>
> Suite 950

Falls Church, VA 22042

Total Yearly
Cost...........................................................\...\........
\$88,750

[Staffing, Operations, & Overhead Costs]{.underline}

A staff of 3 is required for the effective and complete operation of the
campus-based programs Reallocation process. While the FISAP is the
instrument by which institutions request campus-based funding and report
program expenditures, the Campus-Based Reallocation Form is used to
provide information that is needed prior to the annual submission of the
FISAP.

Yearly staff
costs\...\...\...\...\...\...\...\...\.................................................\...\$12,087

The 3 program staff members include managers, accountants and systems
analysts. Of that staff, each of the three employees worked 34 hours per
year on the Reallocation process for a total of 102 hours worked for the
office. This process takes approximately two half-months to complete for
a yearly cost of \$12,087 (102 hours x 3 employees x \$39.50 average
hourly rate).

Yearly overhead
costs\...\...\...\................................................\...\...\.......\...\$1,934

A standard budget estimate of 16% was used to determine the overhead
costs of staff operations including such items as equipment, utilities,
work materials, etc.

Total staff and overhead
costs\...\...\..........................................\..........\$14,021

#####  Total for FISAP and Reallocation Form

Costs for Development of eCampus-Based FISAP on the
Web.............\$458,220

########  Operations & Maintenance Costs to the Federal Government.........\....\$1,065,000

Staffing Operations and Overhead
Costs...................................\...[\$1,127,491]{.underline}

########  Total Costs.....................................................................\...\$2,650,711

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

#####  FISAP

There are no changes in burden. We are adding a total line in Part II,
Section E, but this will be automatically calculated and provides no
extra burden.

#######  Reallocation Form

> There are no changes in burden.

16. **For collections of information whose results will be published,
    outline plans for tabulation and publication.**

Proposed changes to future FISAP submissions would be to have schools
report data on an annual basis instead of cumulative. The Department
will reach out to schools to alert them of this change and see what the
burden would be to the school. The Department would like to make this
change on the FISAP clearance package that would be submitted to OMB in
2009 and have schools begin reporting the annual data on funds received
in 2010.

> The Department is also working to revise the information on the FISAP
> form Section F -- Information on Eligible Aid Applicants Enrolled in
> Your School for Award Year 200X -- 200X, lines 26 -- 40. Changes to
> this information would have an impact on the amount of awards schools
> would receive. These changes would have to be carefully reviewed
> before being implemented. We plan to implement changes either in the
> FISAP Clearance Package submitted in 2009 depending how soon these
> changes can be decided upon, reviewed and implemented.
>
> The Department may also add two lines to Part III, Section A to
> collect data for Perkins Loans that fall under the Mandatory
> Assignment laws in the CCRAA.

######  FISAP

This information is not collected for statistical publication. However,
the Department includes data extrapolated from the FISAP in the Office
of Planning and Evaluation\'s Bi-Annual Evaluation Report, which is sent
to Congress.

#####  Reallocation Form

This information is not collected for statistical 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 I inappropriate.**

######  FISAP

Displaying the expiration date on the FISAP is appropriate.

#####  Reallocation Form

> Displaying the expiration date on the Campus-Based Reallocation From
> is appropriate.

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

#####  FISAP

There are no exceptions to the certification statement.

######  Reallocation Form

#  There are no exceptions to the certification statement.

#