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ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable) **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  ICRAS ICR ID and OMB Number: (XXXX) 1880 - NEW

Revised XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 

### A. Justification 1. Explain the circumstances that make the collection of information necessary. I dentify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or auth orizing the collection of information , or you may provide a valid URL link or paste the applicable section . Please limit pasted text to no longer than 3 pages. Specify the review ty pe of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The collection is necessary to certify the identit y of individuals re questing information under the Freedom of Information Act (FOIA) and Privacy Act (PA). This certification is required under 5 U.S.C. Section 552a(b). 2. Indicate how, b y 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 form is used b y Privacy Act requestors to obtain personal records via regular mail, fax or email. The department will use the information to help identify first - part y requesters with same or similar name when requesting retrieval of their own documents . 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. Use of an electronic signature is acceptable. This form may be filled out and filed electronicall y. This will minimize instances of misinformation and reduce the usage of paper forms to collect necessary information.2

ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable) 4. Describe ef

forts to identify

duplication. Show specificall y wh y an y similar information already available cannot be used or modified f or use for the purposes described in Question 2 above. The files are checked to ensure that a Certificate of Identity is on file. Electronic submission will eliminate the receipt of duplicate copies. There is no similar information collection activity

a lready in use. 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 independentl y 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. This collection of information has no significant impact on small businesses. 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. If the collection activity

is not conducted, the request for personal records would not be granted. It would jeopardize the pro tection of personal information and nor meet the requirements of 5 U.S.C. Section 552a(b).

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 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 generali zed to the universe of study;3

ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable)  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 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. There are no special circumstances associated with this collection. 8. As appli cable, 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 noti ce and describe actions taken by the agency

in response to these comments. Specificall y 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, frequ ency

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 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 circums tances should be explained. A 60 - day and 30 - day

notice was published in the Federal Register in order to solicit comments from the public. No comments were received. 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 ment or gift is associated with this information collection. 10. Describe an y 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 i nstrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy Impact4

ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable) Assessment was completed as indicated on the IC RAS’ Part 2 I C form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 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

– Fede ral 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 Personall y Identifiable Information, OM:6 - 104

– Privacy Ac t of 1974 (Collection, Use and Protection of Personally I dentifiable Information) . If the collection 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. The certifications are maintained by the FOIA offices that provide the individual with the requested information pursuant to 5 U.S.C. Section 552. While no particular statements offering assurances of confidentiality are provided to the individual on the certification form, the FOIA office does comply with PII procedures. A Privacy

Act Statement is included on the form. The text of the statement follows: In accordance with 34 CFR Section 5b.5(b)(2) personal data sufficient to identify the individuals submitting requests by mail under the Privacy Act of 1974, 5 U.S.C. Section 552a, is required. The purpose of this solicitation is to ensure that the records of individuals who are the subject of U.S. Department of Education systems of records are not wrongfully disclosed by the Department. Requests will not be processed if this information is not furnished. False information on this form may subject the reques ter to criminal penalties under 18 U.S.C. Section 1001 and/or 5 U.S.C. Section 552a(i)(3). 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commo nly 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 an y steps to be taken to obtain their consent. No records of a sensitive nature are maintained. 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 g overnment, 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 ty pe: recordkeeping, reporting or third party

disclosure. All narrative should be included in Question 12. Unless directed to do so, agencies should not conduct special survey s to obtain information5

ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable) on wh ich 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 e stimated 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 . (The table should at minimum include Respondent ty pes, Number of Respondent s and Responses, Hours/Response, and Total Hours)  Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifyin g 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 Question 14. It is estimated that 62,000 indi viduals will submit the form and the form takes about 30 minutes to complete and submit, totaling 31,000 hours. 13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not in clude the cost of any hour burden shown in Question s 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 an d 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 s ys tem 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 purchasi ng 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 - OM B 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 business or private practices. Also, these estimates should6

ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable) not include the hourly

costs (i.e., the monetization of the hours) captured above in Question 12 . Total Annualized Capital/Startup Cost: Total Annual Costs (O&M): Total Annualized Costs Requested: There is no new cost or annual cost associated with this collection. 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 an y other expense that would not have been incurred without this collection of information. Agencies also may aggregat e cost estimates from Questions 12, 13, and 14 in a single table. There are no costs to the Federal Government. 15. Explain the reasons for any program changes or adjustments. Generall y, adjustments in burden result from re - estimating burden and/or from econ omic 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 b y ty pe 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) . This is a new collection , therefore all burden is new. This results in a program change increase in burden and responses of 62,000 responses and 31,000 hours respectivel y. 16. For collections of information whose results will be published, outline plans for tabulation and publicatio n. Address an y complex anal yt ical techniques that will be used. The results of this information collection will not be published.7

ICRAS ICR ID and OMB Number: (XXXX) 1880 -NEW Revi sed: 0 9 / 16 /2014 RI N Number: XXXX - XXXX (if applicable) 17. 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 will not be published. 18. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate. ED is not seeking this approval. 19. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. There are no exceptions to the Certification Statement.