FERPA’s Recordkeeping Requirement (34 CFR § 99.32)

We informally contacted eight school officials – three officials at elementary/secondary

school districts and one official at an elementary school and four officials at postsecondary

institutions. Most of the schools we contacted use a paper-based system for recordkeeping, 

while some of the postsecondary institutions use both paper-based and electronic. From our 

informal review, it is clear that the recordkeeping is done at the individual school (as

opposed to the school district at the elementary/secondary level) and the individual 

postsecondary institution. We estimate that an average of .0833 hours (5 minutes) per 

disclosure is required for the recordkeeping requirement. The average number of disclosures

of individual student records per year is based on responses from the eight school officials. 

(Based on the type and size of the school, the number of releases vary.) 

It is not clear that schools recognize that FERPA requires that they record disclosures made 

of personally identifiable information from students’ education records to State authorities, 

such as when a school discloses personally identifiable information on all students in 

attendance to a State education department on the elementary/secondary level or to the State 

postsecondary educational authority on the college level. Without more information on the 

practices of schools in this regard, it is difficult to accurately estimate the specific burden 

hours for this recordkeeping requirement. However, we assume that many of these schools, 

especially at the postsecondary level and more urban school districts, utilize computerized

methods to record disclosures, which would make it less burdensome to record disclosures 

for large numbers of students. Where there are large numbers of disclosures and no 

computerized method is used to indicate that a disclosure occurred, FPCO has advised 

schools that they may utilize a single notice about the mass disclosure. When a parent or 

student requests access to his or her record of disclosure, the school may provide the notice 

with the information concerning the disclosure to the parent or student at the time of the 

request, thereby minimizing the burden on the school. However, because these recordations 

are not exempt from FERPA’s recordkeeping requirement, we have included an estimate for 

the burden of recording disclosures of all students in attendance to State authorities. We 

estimate that schools must share this information with State officials twice a year and 

estimate that it would take schools 1 hour to either make the recording via their computer 

system or develop a notation and make it available to parents or students asking to inspect 

this record. As explained elsewhere, it is our administrative experience that few parents and 

students request to see this record. 

For the general recordkeeping requirement of § 99.32(a) for recordation of individual 

disclosures, following is a breakdown of individual schools (public elementary, secondary, 

or combined) and postsecondary institutions:

No. of Schools: 97,382

Average No. of Disclosures: x 192

# of Responses 18,697,344
2

Hours/Response: x .0833

Burden Hours 1,557,489 

No. of Postsec. Inst.: 6,463

Average No. of Disclosures: x 192

# of Responses 1,240,896

Hours/Response: x .0833

Burden Hours 103,367

Elementary/Secondary School Burden Hours: 1,557,489

Postsec. Inst. Burden Hours: + 103,367

Total Burden Hours for recordation 

of individual disclosures: 1,660,856

For the recordkeeping requirement for disclosures of all students in attendance to State 

educational authorities, following is a breakdown of individual schools (public elementary, 

secondary, or combined) and postsecondary institutions:

No. of Schools: 97,382

Average No. of Disclosures: x 2

# of Responses 194,764

Hours/Response: x 1

Burden Hours 194,764 

No. of Postsec. Inst.: 6,463

Average No. of Disclosures: x 2

# of Responses 12,926

Hours/Response: x 1

Burden Hours 12,926

Elementary/Secondary School Burden Hours: 194.764

Postsec. Inst. Burden Hours: + 12,926

Total Burden Hours for recordation 
3

of disclosures of all students: 207,690

Total Burden Hours for recordation 

of individual disclosures: 1,660,856

Total Burden Hours for recordation 

of disclosures of all students: 207,690

Total Burden Hours for Recordation 1,868,546

 

The number of school districts and the number of postsecondary institutions subject to 

FERPA is based on the number of public school districts and the number of Title IV 

postsecondary institutions, as reported in the National Center for Education Statistics’ 

(NCES’) Digest of Education Statistics. See 

http://nces.ed.gov/programs/digest/d07/tables/dt07_005.asp. The number of affected 

schools reported to OMB in previous years was higher, but we believe this number that is 

based on NCES’ count is more accurate.