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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

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 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 request is for an extension of the current approval of the policies and procedures for 

determining satisfactory academic progress (SAP) as required in Section 484 of the 

Higher Education Act of 1965, as amended (HEA). A link to the Satisfactory Academic 

Progress regulations is provided at 34 CFR 668.34. 

These regulations identify the policies and procedures to ensure that students are making 

satisfactory academic progress in their program at a pace and a level to receive or 

continue to receive Title IV, HEA program funds. If there is lapse in progress, the policy

must identify how the student will be notified and what steps are available to a student 

not making satisfactory academic progress toward the completion of their program, and 

under what conditions a student who is not making satisfactory academic progress may

continue to receive Title IV, HEA program funds.

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.

Institutions are required to confirm satisfactory academic progress by a student in order 

to make initial or continuing disbursements of federal student financial aid. The 

institutions collect documentation to confirm the information provided on the Free 

Application for Federal Student Aid based on the requirements the Department issues in 

an annual Federal Register. The information is held in the institutions files and is made 

available to the Department during program reviews. 

Section 668.34(a) – Satisfactory academic progress policy.

This section of the regulations requires an institution to establish a reasonable 

satisfactory academic progress policy to determine a student’s eligibility for Title IV, 

HEA program funds. The policy must identify requirements specifying –

 

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Please limit pasted text to no longer than 3 paragraphs.
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

 it is at least as strict as it is for students who do not receive Title IV, HEA 

program funds

 it has a consistent application of standards to all students

 the timeframe for the review of when a student’s academic progress is evaluated

 the pace that a student must progress to ensure completion of their academic 

program within the maximum timeframe

 how transferred credits affect the pace and maximum timeframe for program 

completion

 how “financial aid warning” and “financial aid probation” statuses are used in 

progress calculations

 a description of the appeal process and how it can be used to reestablish Title IV 

aid eligibility and if a school doesn’t have an appeal process how a student may

regain eligibility for assistance

 a notification of the results of a student’s evaluation that impact their eligibility

for Title IV, HEA funds.

Section 668.34(c) – Institutions that evaluate satisfactory academic progress at the end of 

each payment period.

This section of the regulations identifies the process that is followed for 

institutions that evaluate a student’s SAP at the end of a payment period. This section 

specifies that an institution’s policy may provide for disbursement of Title IV aid to a 

student not meeting SAP under certain circumstances. This includes policies that 

automatically place a student who is not meeting SAP on “financial aid warning”.

Section 668.34(d) – Institutions that evaluate satisfactory academic progress annually or 

less frequently than at the end of each payment period.

This section of the regulations identifies the process that is followed for 

institutions that evaluate a student’s SAP on an annual basis. This section specifies that 

an institution’s policy may provide for disbursement of Title IV aid to a student not 

meeting SAP under certain circumstances. This includes policies that require a student to 

file an appeal and either having a determination made by the school that the student 

should meet SAP standards after the subsequent payment period or if the school 

develops, with the student, an academic plan which if successfully completed will ensure 

the student meets the institution’s SAP standards at a specific time.

Section 600.55(g)(1) & (2) – Other Criteria.

This regulation requires foreign graduate medical schools to apply existing 

regulations in SAP for establishing maximum timeframes in which a student must 

complete their educational program and requires that a student complete their educational 

program in 150 percent of the published length of the program. The regulations require 

foreign graduate medical schools to document the educational remediation it provides to 

assist students in making SAP.

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 
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

decision of adopting this means of collection. Also describe any consideration given to using 

technology to reduce burden.

The institution may provide their policy and procedure information to students via an 

Internet or Intranet Web site as an efficient method to provide the SAP requirements.

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.

There is no duplication of data as a result of the collection of this information.

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.

No small businesses are impacted by this collection.

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.

The statute requires that the student’s academic progress be evaluated at least at the end 

of each academic year or the equivalent. Evaluation at any longer interval could risk 

funds being disbursed to ineligible students.

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
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

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 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to protect 

the information’s confidentiality to the extent permitted by law.

The information collection requirements require no special circumstances.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as 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 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.

There will be a 60-day and a 30-day Federal Register notice published seeking public 

comment. This is the 60-day notice.

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

of contractors or grantees with meaningful justification.

No payments or gifts will be provided to the respondents.

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.

 

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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)
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

There is no assurance of confidentiality provided to institutions for the submission of this 

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. 

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

The Department is not requesting any sensitive data.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (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 

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. 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 the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 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.

Annual Hour Burden for Respondents/Recordkeepers

The burden hours calculated below include time for reviewing the changes in 

regulations; for determining the method and means to incorporate changes; and for 

developing or updating systems, forms and formats for gathering the required 

information. The burden is all related to recordkeeping.

Section 668.34 (a) – Satisfactory academic progress policy

We anticipate that it will take the 5,838 institutions 3 hours to review and update, 

as needed, their institutional policies, processes, and notifications.
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

# of Respondents # of Responses Hrs/Response Burden Hours

For-profit institutions

2,199 2,199 X 3 hrs 6,597

Private institutions

1,743 1,743 X 3 hrs 5,229

Public institutions

1,896 1,896 X 3 hrs 5,688

TOTAL 

5,838 5,838 17,514

Previous totals

5,709 5,709 17,127

A net change from previous burden calculation 

+129 +129 +387

Section 668.34(c) – Institutions that evaluate satisfactory academic progress at the end of 

each payment period.

We estimate that 55% of eligible institutions review for SAP at the end of each 

payment period. 55% of the 21,026,924 non-rejected FAFSA applications completed for 

the 2012-2013 award year equals 11,564,808 x 2 institutional reviews per year = 

23,129,616 evaluations. Additionally, we estimate that 7% of these 11,564,808 FAFSA 

filers (809,537 x 2 reviews per year = 1,619,074 evaluations) will not meet the SAP 

requirements at the institution and will require additional evaluation and consultation 

with the student by the institution.

# of Respondents # of Responses Hrs/Response Burden Hours

For-profit institutions – Evaluation of all students for SAP

* 8,789,254 X .02 175,785

Private institutions – Evaluation of all students for SAP

* 6,938,885 X .02 138,778

Public institutions – Evaluation of all students for SAP

* 7,401,477 X .02 148,030

Individuals not meeting SAP requirements

809,537 x 2= 1,619,074 X .17 275,243

For-profit institutions – Working with students not meeting SAP

* 615,248 X .25 153,812

Private institutions – Working with students not meeting SAP

* 485,722 X .25 121,431

Public institutions – Working with students not making SAP

* 518,104 X .25 129,526

TOTAL

 809,537 26,367,764 1,142,605

Previous total

 371,991 11,930,328 516,981
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

A net change from previous burden calculation 

 +437,546 +14,437,436 +625,624

*-To avoid double counting the number of respondents when developing these tables the 

number of institutions is only included in the totals for section 668.34(a).

Section 668.34(d) – Institutions that evaluate satisfactory academic progress annually or 

less frequently than at the end of each payment period.

We estimate that 45% of eligible institutions review for SAP annually. 45% of 

the 21,026,924 non-rejected FAFSA applications completed for the 2012-2013 award 

year equals 9,462,116 evaluations. Additionally, we estimate that 7% of these 9,462,116 

FAFSA filers will not meet the SAP requirements at the institution and will require 

additional evaluation and consultation with the student by the institution.

# of Respondents # of Responses Hrs/Response Burden Hours

For-profit institutions – Evaluation of all students for SAP

* 3,595,604 X .02 71,912

Private institutions – Evaluation of all students for SAP

* 2,838,635 X .02 56,773

Public institutions – Evaluation of all students for SAP

* 3,027,877 X .02 60,558

Individuals not meeting SAP requirements

662,348 662,348 X .17 112,599

For-profit institutions – Working with students not meeting SAP

* 251,692 X .25 62,923

Private institutions – Working with students not meeting SAP

* 198,705 X .25 49,676

Public institutions – Working with students not making SAP

* 211,951 X .25 52,988

TOTAL 

 662,348 10,786,812 467,429

Previous total

 603,327 9,732,636 412,748

A net change from previous burden calculation 

 +59,021 +1,054,176 +54,681

*-To avoid double counting the number of respondents when developing these tables the 

number of institutions is only included in the totals for section 668.34(a).

Subpart E of Section 600 - Eligibility of Foreign Institutions

Section 600.55 – Other criteria.

# of Respondents # of Responses Hrs/Response # of Burden 

Hours

For-profit institutions

4 4 X 2.5 10
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

Private institutions

5 5 X 2.5 13

Public institutions 

18 18 X 2.5 45

TOTAL

 27 27 68

Previous total

 71 71 178

A net change from previous burden calculation 

 -44 -44 -110

GRAND TOTAL

 1,477,750 37,160,441 1,627,616

Current Burden 

 984,598 21,672,244 977,032

A net change from previous burden calculation 

 +493,152 +15,488,197 +650,584

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.)

 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 
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

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usual business 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 is no new system start-up costs associated with these final regulations.

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.

There are no additional costs to the Federal government as a result of the final regulation.

15. Explain the reasons for any 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 materially 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 type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

Reasons for Changes to Burden Hour Estimated

This collection extension is an adjustment in burden based on the increase of 650,584

burden hours. This increase is caused by an increase in the number of students for whom 

a determination of satisfactory academic progress must be made on an annual or semiannual basis and a slight increase in the number of eligible institutions that must perform 

these determinations.

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.

The results of the collection of information will not be published.
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ICRAS Tracking and OMB Number: (1472) 1845-0108 v2 Revised: 08/28/2013

RIN Number: XXXX-XXXX (if applicable)

17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

The Department is not seeking approval to not display an expiration date. ED will 

publish a Notice in the Federal Register announcing the OMB number and expiration 

date once approved.

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

Paperwork Reduction Act.

The Department is not requesting any exceptions to the “Certification of Paperwork 

Reduction Act Submissions.”