ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

Experimental Sites Data Collection Instrument

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 hard copy of the appropriate section of each statute and 

regulation mandating or authorizing the collection of information, or you 

may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with 

change, reinstatement without change). If revised, briefly specify the 

changes. If a rulemaking is involved, make note of the sections or changed 

sections, if applicable.

This is a request for a new collection. The U. S. Department of Education is 

requesting OMB clearance of the attached data collection instrument that 

constitutes paperwork requirements. The Secretary selects institutions for 

voluntary participation in the Experimental Sites Initiative. Institutions volunteer 

to become an experimental site to provide recommendations on the impact and 

effectiveness of proposed regulations or new management initiatives. Participants 

are exempt from specific statutory and regulatory requirements while conducting 

the experiments. The Department approved alternative approaches in 8 areas of 

student financial aid processes to test ways to address federal objectives and meet 

the needs of aid administrators and recipients. Those experiments are listed 

below:

 Experiment 1--Federal Pell Grant Program--Eligibility of students with 

bachelor's degrees who enroll in vocational or career programs.

 Experiment 2--Federal Pell Grant Program--Eligibility of students enrolled 

in certain short-term training programs.

 Experiment 3--Direct Loan Program--Single disbursement of a one-term 

loan for study abroad students.

 Experiment 4--Direct Loan Program--Early disbursement for study abroad 

students and for students enrolled in foreign institutions.

 Experiment 5--Direct Loan Program--Unequal disbursements.

 Experiment 6--Direct Loan Program--Limiting unsubsidized loan 

amounts.

 Experiment 7--PLUS Loans for parents of students with intellectual 

disabilities.

 Experiment 8--Student Eligibility--Eligibility of students with intellectual 

disabilities who are also enrolled in high school.

 

1

Please limit pasted text to no longer than 3 paragraphs.
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

The experiments above relate to a number of programs authorized under Title IV

of the Higher Education Act, such as the Federal Family Education Loan

Program, the William D. Ford Federal Direct Loan Program and Federal Pell 

Grant Program. Institutions report annually on their experiences. The collection 

of this information is authorized under section 487A(b) of the Higher Education 

Act of 1965, as amended. 

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.

FSA and its partners can change the way policy fosters or impedes the 

administration of student aid. The elements of customer satisfaction, 

simplification, fewer burdens for students and institutions, and easy access to 

funds, are truly a part of regulatory reform. Thus, FSA has committed to reform 

current practices and operations by engaging in an interactive process of 

collecting information and using it to improve program services and processes. 

The Experimental Sites Initiative is one approach FSA can use for change. 

Institutions are given the flexibility to test different procedures to carry out the 

intent of regulations, whereby the Department can analyze the data and obtain 

information for Title IV regulatory and legislative changes. Thus, the Department 

needs this information in its ongoing initiative to improve the financial aid 

delivery services to students and the postsecondary institutions they attend. 

Additionally, working with Congress, the Department can use this data to make 

informed decisions for future reauthorization. 

To obtain uniform data, the Department and participating institutions developed 

this data collection instrument. 

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 given to using technology to 

reduce burden.

This data collection effort is a web-based format supported by the security

architecture environment and staff from the Chief Information Office. This 

website requires institutions to securely logon and submit data. 

There is an email address and telephone number available for participants to 

contact staff with questions or requests for assistance. The email address and 

telephone number is posted on the Experimental Sites website. Within the 

reporting tool is a database that collects information in order for institutions to 
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

meet their annual requirement. This database will help ensure the efficiency and 

completeness of the data collection process.

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 Item 2 above.

This reporting tool is the Department's effort to evaluate the experiments. The 

information necessary to review the experimental data focuses on "experimental" 

descriptions and therefore does not represent a duplication of other information 

collected for other purposes or by other entities.

There is no information available from any other source that will enable ED/FSA 

to evaluate the results of this data collection under the provisions of the Higher 

Education Amendments of 1998.

5. If the collection of information impacts small businesses or other small 

entities, describe any methods used to minimize burden. A small entity may 

be (1) a small business which is deemed to be one that is independently 

owned and operated and that is not dominant in its field of operation; (2) a 

small organization that is any not-for-profit enterprise that is independently 

owned and operated and is not dominant in its field; or (3) a small 

government jurisdiction, which is a government of a city, county, town, 

township, school district, or special district with a population of less than 

50,000.

The information is collected from 2-and 4-year institutions of higher education 

rather than from small businesses or by other 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.

This information must be collected in order to implement the provisions of section 

487A(b) of the HEA. Under Section 487A(b) institutions will participate as 

experimental sites to provide recommendations to the Secretary on the impact and 

effectiveness of proposed regulations or new management initiatives.

These data collection instruments provide needed information. These report 

formats will:

 Provide a more comprehensive picture of aggregated data

 Provide more detailed information

 Identify impacts of regulatory relief

 Examine impact on Federal student assistance programs

The results of these experiments will help the Department in its continuing efforts 
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

to improve Title IV program administration. When feasible, the Department will 

use the information gathered through this initiative to revise existing regulations 

and to make recommendations to Congress for statutory changes. Failure to 

collect and analyze this information will prevent the Department from evaluating 

important information that may impact simplification in the Federal student 

assistance programs. 

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;

 requiring respondents to submit more than an original and two copies 

of any document;

 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 than can be generalized to the universe of 

study;

 requiring the use of a statistical data classification that has not been 

reviewed and approved by OMB;

 that includes a pledge of confidentiality that is 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 that 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.

None of the special circumstances listed apply to this data collection.

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. 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.

Describe efforts to consult with persons outside the agency to obtain their 

views on the availability of data, frequency of collection, the clarity of 
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

instruction and record keeping, disclosure, or reporting format (if any), and 

on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be 

obtained or those who must compile records should occur at least once every 

3 years – even if the collection of information activity is the same as in prior 

periods. There may be circumstances that may preclude consultation in a 

specific situation. These circumstances should be explained.

Department staff members solicited informal views and comments on reporting 

measures from a participating institution. A separate 60-day Federal Register

notice followed by a 30-day Federal Register notice will be published to solicit 

public comments.

9. Explain any decision to provide any payment or gift to respondents, other 

than remuneration of contractors or grantees.

The Department will not provide payment or gifts to the respondents participating 

in this initiative. All participation will be voluntary.

10. Describe any assurance of confidentiality provided to respondents and the 

basis for the assurance in statute, regulation, or agency policy. If personally 

identifiable information (PII) is being collected, a Privacy Act statement 

should be included on the instrument. Please provide a citation for the 

Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement 

with a legal citation that authorizes the pledge of confidentiality should be 

provided.2If the collection is subject to the Privacy Act, the Privacy Act 

statement is deemed sufficient with respect to confidentiality. If there is no 

expectation of confidentiality, simply state that the Department makes no 

pledge about the confidentially of the data.

No assurance of confidentiality is provided to the respondents. There is no 

requirement for such an assurance in statute.

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. The justification should include the reasons 

why the agency considers the questions necessary, the specific uses to be 

made of the information, the explanation to be given to persons from whom 

 

2

Requests for this information are in accordance with the following ED and OMB policies: Privacy Act 

of 1974, OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB 

Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, 

OMB M-03-22 – OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 

2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 

(Collection, Use and Protection of Personally Identifiable Information)
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

the information is requested, and any steps to be taken to obtain their 

consent.

No questions of a sensitive nature will be included in the data collection 

information package.

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

statement should :

 Indicate the number of respondents, frequency of response, annual hour 

burden, and an explanation of how the burden was estimated. Unless 

directed to do so, agencies should not conduct special surveys to obtain 

information on which to base hour burden estimates. Consultation with 

a sample (fewer than 10) of potential respondents is desirable. If the 

hour burden on respondents is expected to vary widely because of 

differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, 

estimates should not include burden hours for customary and usual 

business practices.

 If this request for approval covers more than one form, provide separate 

hour burden estimates for each form and aggregate the hour burdens in 

item 16 of IC Data Part 1.

 Provide estimates of annualized cost to respondents of the hour burdens 

for collections of information, identifying and using appropriate wage 

rate categories. The cost of contracting out or paying outside parties for 

information collection activities should not be included here. Instead, 

this cost should be included in Item 14.

Each of the 25 respondents will submit a report format for one or more of the 

eight experiments. The estimated total of the hour burden of the data collection 

effort is 275 hours or an average of 11 hours per respondent. The total cost for 

the reporting period is estimated at $9,350.00 or an average or $374 per 

institution.

Exhibit 1

RESOURCE HOURS/RATE NUMBER MONETARY COST

Computer Personnel 4 hours/$50 25 Schools $5,000

Financial Aid Personnel 5 hours/$30 25 Schools $3,750

Clerical Personnel 2 hours/$12 25 Schools $600

TOTAL $9,350

13. Provide an estimate of the total annual cost burden to respondents or record 

keepers resulting from the collection of information. (Do not include the cost 

of any hour burden shown in Items 12 and 14.)
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

 The cost estimate should be split into two components: (a) a total capital 

and start-up cost component (annualized over its expected useful life); 

and (b) a total operation and maintenance and purchase of services 

component. The estimates should take into account costs associated with 

generating, maintaining, and disclosing or providing the information. 

Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of 

capital equipment, the discount rate(s), and the time period over which 

costs will be incurred. Capital and start-up costs include, among other 

items, preparations for collecting information such as purchasing 

computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present 

ranges of cost burdens and explain the reasons for the variance. The 

cost of contracting out information collection services should be a part of 

this cost burden estimate. In developing cost burden estimates, agencies

may consult with a sample of respondents (fewer than 10), utilize the 60-

day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking 

containing the information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or 

services, or portions thereof, made: (1) prior to October 1, 1995, (2) to 

achieve regulatory compliance with requirements not associated with the 

information collection, (3) for reasons other than to provide information 

or keep records for the government, or (4) as part of customary and 

usual business or private practices.

There are no additional respondent costs associated with this data collection other 

than the hour burden estimated in item 12. 

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 (such as equipment, 

overhead, printing, and support staff), and any other expense that would not 

have been incurred without this collection of information. Agencies also may 

aggregate cost estimates from Items 12, 13, and 14 in a single table.

The annualized cost to the Federal Government is $6,975. This cost estimate was 

derived in the following manner:

Exhibit 2

RESOURCE HOURS/RATE NUMBER MONETARY COST

Program Analysts, GS-13 3 hours/$45 25 Schools $3,375
ICRAS Tracking and OMB Number: (1969.02) 1845-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)

Estimated cost for data 

analysis and final report 

(Program Analyst, GS-13)

80 hours/$45 $3,600

TOTAL $6,975

15. Explain the reasons for any program changes or adjustments to #16f of the 

IC Data Part 1 Form.

This is a new collection package we anticipate 25 respondents at 11 hours per 

response as indicated in Question 12.

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. Provide the time schedule for the entire project, including 

beginning and ending dates of the collection of information, completion of 

report, publication dates, and other actions.

Participating institutions are required to submit an annual report describing the 

results, any corrective actions taken, and specific information relating to the 

performance measure or alternative used in each experiment. 

After each year of data collection, FSA will produce an annual report based on 

analysis of the data. These reports should provide critical information to help 

FSA/ED/Congress consider streamlining Title IV regulations and requirements. 

With the automated data collection effort, the focus of the reports has moved 

toward judgments about impact and effectiveness and/or special reports. 

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.

All data collection instruments will include the OMB expiration date.

18. Explain each exception to the certification statement identified in the 

Certification of Paperwork Reduction Act.

No exceptions are requested.
ICRAS Tracking and OMB Number: (1969.02) 1845

-NEW v1 Revised: 3/7/2013

RIN Number: XXXX-XXXX (if applicable)