1

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable)
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **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 cop y 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 section 1 . Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This request is for an extension of the information collection supporting the policies and reporting requirements contained in S ubpart E of P art 668

– Verification and Updating of Student Aid Application I nformation . S ections 668.53, 668.54, 668.55, 668.56, 668.57, 668.59 and 668.61 contain information collection requirements (OMB control number 1845

- 0041). Th is subpart governs the verification and updating of the Free Application for Federal Student Aid (FAFSA) used to calcul ate an applicant’s Expected Family Contribution (EFC) for purposes of determining an applicant’s need for student financial assistance under T itle IV of Higher Education Act of 1965, as amended (HEA). The collection of this documentation helps ensure that students (and parents in the case of PL US loans) receive the correct amount of T itle IV program assistance by providing accurate information to calculate an applicant’s expected family contribution. There has been no change to the regulatory language s ince the prior information collection filing. The regulations require the verification process to include the updating of a student’s marital status during the award year when the institution determines that the update is necessary

to address an inequity or reflect more accuratel y the applicant’s ability to pay . The regulations identify the number of items to be verified as an average of three data elements as selected on an individual basis. The regulations require that all data changes be transmitted to the Department in order to insure that our s ys tems contain correct data. 2. I ndicate 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. The regulations require participating institutions to inform an applicant selected for verification with a clear explanation of the documentation needed to satisfy the verification requirements, the deadline for the submissio n of those documents, and the consequences of an applicant’s failure to provide the required documentation within the

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable) specified time period. Subsequently , the institution will review the submitted documentation and compare the data with that which was ori ginall y submitted on the FAFSA. When the data contained on the verification documentation differs from the FAFSA data, the original FAFSA data must be corrected. Institutions will utilize the verif ication and updating regulation information to record an y changes to application data to ensure that onl y eligible students receive Title IV , HEA student financial assistance. And b y an institution’s reporting of confirmation of student information or updates to student information , the Department will have more accurate data to use to determine trends or to insure that eligible students continue to have access to limited federal aid funds. 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 an y consideration given to using technology

to reduce burden. Institutions are encouraged to use computer and Internet technology to image, transmit, and receive the supporting documents. Changes to FAFSA information are reported using the Department’s FAA Access to CPS Online sy stem or the Electronic Data Exchange (EDE) , which are both web

- based. Students who filed the FAFSA electronically

are also able to make changes to the record electronicall y using the Personal Identification Number (PIN) provided b y the Department to ensur e a more secure exchange of information. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in I tem 2 above. The student completes t he Free Application for Federal Student Aid (FAFSA) using self

reported data and submits the data b y paper or electronicall y to the Department. Those students selected for verification by the Secretary

must submit documentation to support the data as orig inall y provided on the FAFSA. The submission of supporting documentation is not duplicated during an y other part of the application process. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y 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 in dependently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city , count y, town, township, school district, or special district with a population of less than 50,000. No small business es are impacted b y this collection.3

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable) 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. Without these an nual data collections institutions would not be able to comply with the statutory verification requirements, resulting in students receiving more aid than they would otherwise be eligible to receive, based solely upon self

- reported data. The Department’s selection of applicants for the verification process is based upon annual studies it conducts to identify applicant classes that are most prone to report erroneous data. 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 quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;
 requiring responde nts 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 y ears;  in connection with a statistical survey , t hat 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 b y 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 unnecessaril y i mpedes sharing of data with other agencies for compatible co nfidential 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. This information collection requirement requires no special circumstances. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 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 b y the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consul t 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 an y), and on the data elements to be recorded, disclosed, or re ported.4

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable) 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 y ears
– 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. There were no comments to the 60

- day Federal Register notice. This is the 30

- day Federal Register notice published seeking public comme nt. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification

. No pay ments or gifts will be provided to the respondents. 10. Describe an y assurance of conf identiality

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 ci tation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the col lection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. No assurance of confidentiality is provided to respondents. Submission of required documents is required for applicants selected for verification. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and at titudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y t he agency considers the questions necessary , the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and an y steps to be taken to obtain their consent. The Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for

- profit, private sector

– not
- for

- profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was

2 Requests for this information are in accordance with the follow ing 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 Impl em enting 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)5

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable)

estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agenci es should not conduct special survey s 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 widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, 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 the ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Respo nse, and Total Hours)
 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outside parties for information col lection activities should not be included here. Instead, this cost should be included in I tem 14. Subpart E

– Verification and Updating of Student Aid Application I nformation sections 668.53, 668.54, 668.55, 668.56, 668.57, 668.59 and 668.61 contain coll ection requirements (OMB control number 1845

- 0041)

. Section 668.53

– Policies and procedures. The regulations require that all Title IV program participating institutions establish and use written policies and procedures for the verification of informat ion supplied by aid applicants on the FAFSA. These procedures must be include timeframes for the request for and submission of documentation, applicant responsibilities in the verification process including consequences of the failure to provide the reque sted data, among other regulatory elements. Because the items from the FAFSA selected for verification change annually , we estimate that each participating institution will require 2 hours to review their procedures and update an y programming to capture t he verification items for that award y ear. AFFECTED PARTIES : # of Respondents # of Responses Hrs/Response # of Burden Hours For
- profit institutions 2,199 2,199 X 2 hours 4,398 Private institutions 1,743 1,743 X 2 hours 3,486 Public institutions 1,896 1,896 X 2 hours 3,792 **TOTAL 5,838**  **5,838 11,676** 6

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable) Section 668.54

– Selection of an applicant’s FAFSA information for verification. The regulations require that the institution perform verification on all applicants at their institution who are selected by the Department of Education. The regulations also allow for institutions to select applications for institutional verification based on their written policies and procedures. There are also listed a llowed exclusions from the verification process. Because the selection process would be addressed in the updating of policy and procedures and the updating of an y prog rams at the institution we are not including an y burden hours for this section of the reg ulation.
Section 668.55

– Updating information. T he regulations require that all applicants update all dependency status changes throughout the award ye ar, update changes in household size , the number in the household attending postsecondary

educational institutions throughout the award y ear , and under certain situations a financial aid administrator can include changes in an applicant’s marital status. We estimate that approximately ten pe rcent of the approximate 21 million FAFSA applicants will be required to update information listed above. AFFECTED PARTIES : # of Respondents # of Responses Hrs/Response # of Burden Hours Individuals * * 2 , 100 ,000 X 0.08 1 68 , 0 00 Proprietary

I nstitutions * 798 , 0 00 X 0.17 135 , 660 Private Not

- For Profit Institutions

* 630,000 X 0.17 107 , 100 Public I nstitutions

* 672 , 000 X 0.17 114 , 240 **TOTAL** ***** **4 ,**  **200 ,000**  **525 ,**  **0 00**  Note
- A n asterisk (*) is used to avoid double count ing the same respondents that has been identified in one of the section breakouts. The double asterisk denotes this group as a subsection of the individuals identified in section 668 .57 and is used to avoid double counting the same respondent.
Section 668.56

– In formation to be verified. The regulations specify

that the Secretary

will publish an annual listing of FAFSA information that may

be required to be verified. The Federal Re gister includes a range of information that applicants will need to confirm and the ty pes of acceptable documentation that is to be submitted to substantiate the previousl y provided information on the FA F SA for each of the items identified.7

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable) The review of the Federal Register identify ing the verification classifications is part of the annual review of the institution’s policies and procedures identified in Section 668.53, there is no additional burden assessed here.
S ection 668.57

– Acceptable documentat ion. The regulations clarify

acceptable documentation for the specified areas for verification. The regulations also allow the institutions to accept income information provided on the FAFSA if it has been obtained directly from the Internal Revenue Servi ce during the initial application process through the IR S Data Retrieval process when the retrieved data has not been changed by the applicant. The Department selected about 30 percent of the approximate 21 million FAFSA filers in the 2012

- 2013 award ye ar . We anticipate it will take the applicant an average of seven minutes to review the verification request and locate the requested documents to provide to the institution. Affected Parties: # of Respondents # of Responses Hrs/Response # of Burden Hours Individuals 6,300,000 6,300,000 X 0 .12 756,000 Proprietary

I nstitutions * 2 , 394 ,000 X 0 .12 2 87 , 28 0 Private Not

- For Profit Institutions * 1, 890 ,000 X 0 .12 226 , 8 00 Public In stitutions * 2 , 016 ,000 X 0 .12 2 4 1,9 2 0 **TOTAL 6,300,000**  **12 ,**  **6 00,000**  **1,512 ,000**  Note
- An asterisk (*) is used to avoid double counting the same respondents that has been identified in one of the section breakouts.
Section 668.59

– Consequences of a change in application information. The regulations require that all changes to the applicant’s FAFSA information resulting from verification be submitted to the Department for those applicants receiving aid under any of t he subsidized student financial assistance programs. Of the approximate 2 1 million applicants in the 2012

- 2013 award year, we estimate that about 6

. 3 million applicants will be selected for verification. Based upon the average number of transactions as a consequence of a change in FAFSA information, we believe that the 6

. 3 million applicants verified will have an average of 2

. 5 transactions per applicant selected to complete the verification/data correction process yi elding 15,750,000 responses. W e expect the average amount of time per response to be 7.4 minutes (.12 hours) for a total of 1,890,000 hours of burden.8

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable)
Affected Parties: # of Respondents # of Responses Hrs/Response # of Burden Hours Proprietary

I nstitutions * 5,985,000 X 0.12 718,200 Private Not

- For Profit Institutions * 4,725,000 X 0.12 567,000 Public I nstitutions * 5,040,000 X 0.12 604,800 **TOTAL** * **15,750,000 1,890,000**  Note
- An asterisk (*) is used to avoid double counting the same respondents that has been identified in one of the section breakouts.
Section 668.61

– Recovery of funds from interim disbursements. The regulations outline the efforts that institutions must make to recover funds from students w ho received an interim disbursement of Title I V, HEA student financial assistance and who, through the verification process, are determined to have received more funding than they were eligible to receive. Due to the risks of owing repay ments of program f

unds for students who do not complete verification or are shown to be ineligible due to the completion of verification few institutions process interim disbursements. Therefore the Department has determined that an y burden on the institutions would be neg ligible

. A summary

is of the proposed burden is noted below: **# of Respondents # of Responses**  **# Hrs of Burden Section 668.53**  **- Policies and Procedures** 

5,838 5,838 11,676 **Section 668.55**

**– Updating information** 

* 4 , 200 ,000 525 , 00 0 **Section 668.56**

**– Information to be verified** 

N/A N/A N/A **Section 668.57**

**– Acceptable documentation**  6,300,000 12 , 6 00,000 1,512 ,000 **Section 668.59**

**– Consequences of a change in FAFSA information** 

* 15,750,000 1 , 890 , 0 00 **Section 668.61**

**– Recovery of funds from interim disbursements** 

N/A N/A N/A Sub total 6, 305 ,83 8 3 2 , 555 , 838 3, 938 , 676 Current Inventory **9,859,207 33,670,371**  **4,713,934**9

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable) **Net decrease**

**- 3,553,369**  **- 1,114,533**  **- 775,258** 
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 ho ur burden shown in I tems 12 and 14.)

 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 comp onent. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. I nclude descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, exp ected 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 widel y, 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 anal ys is 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 bu siness or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : There are no start

– up costs associated with these regulatory changes. 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 fr om I tems 12, 13, and 14 in a single table. There are no additional costs to the government.10

ICRAS Tracking and OMB Number: (1416) 1845

- 0041 v 8 Revised: 11 / 8 /2013 RIN Number: XXXX

- XXXX (if applicable)
15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result from re

- estimating burden and/or from economic phenomenon outside of an agency ’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materiall y changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)

. The decrease of 775,258 burden hours is due to the co ntinued streamlining and automation of the verification process. The ability of an individual to retrieve his or her financial information directly from the Internal Revenue Service (I RS) when completing the Free Application for Federal Student Aid (FAFSA) has decreased the number of verification interactions institutions must have with students who are usi ng the FAFSA on the Web application which helps to prevent an d combat fraud, waste and abuse. 16. For collections of i nformation whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collectio n of information, completion of report, publication dates, and other actions. The results of the collection of information will not be published. 17. If seeking approval to not display the expiration date for OMB approval of the information collection, e xplain the reasons that display would be inappropriate. ED is not seeking approval to not display an expiration date. The OMB expiration dates will be display ed in the Federal Register once approved. 18. Explain each exception to the certification stat ement identified in the Certification of Paperwork Reduction Act. ED is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submissions.”