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ICRAS ICR ID and OMB Number: (2027) 1880-NEW

Revised: 04/30/2014

Family Educational Rights and Privacy (FERPA) Act E-Complaint Form

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

ICRAS ICR ID and OMB Number: (2027) 1880-NEW

Revised 04/30/2014

A. Justification 

1. Necessity of Information Collected.

The Family Educational Rights and Privacy Act (FERPA) is codified at 20 U.S.C. § 

1232g. The purpose of FERPA is to protect the privacy of students’ education records. 

FERPA affords certain rights to parents and to eligible students (a student who has 

reached 18 years of age or is attending a postsecondary institution at any age) with 

respect to students’ education records. FERPA applies to educational agencies and 

institutions that receive funds from any program administered by the Department of 

Education. The regulations are found at 34 CFR Part 99. 

2. Purpose of Use of Information Collected.

The Family Policy Compliance Office (FPCO) is the office responsible for administering 

the FERPA. FPCO provides technical assistance to educational agencies and institutions 

to improve their understanding of and ensure their compliance with requirements 

concerning student education records under FERPA. FPCO also reviews, investigates, 

and processes complaints of alleged violations of FERPA filed by parents and eligible 

students. FPCO’s authority to investigate, review, and process complaints extends to 

allegations of violations of FERPA of any recipient of Federal Department of Education 

funds under a program administered by the Secretary (e.g., schools, school districts, 

postsecondary institutions, state educational agencies, and other third parties that receive 

Department funds). Generally, FPCO cannot investigate complaints against private and 

parochial elementary and secondary schools as these schools are not subject to FERPA, 

unless such private schools receive federal education funds. As fully investigating 

complaints of alleged violations takes time, we ask parents and students filing complaints

to read carefully accompanying information prior to completing and submitting the

complaint form. 

3. Consideration of Improved Information Technology.

The advancement of and more common use of computer systems have dramatically

reduced the burden of producing information to be submitted in a complaint. Parents no 

longer have to hand-write letters of complaints and can easily utilize computers and 

agency Web sites for submitting inquiries and complaints. 
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ICRAS ICR ID and OMB Number: (2027) 1880-NEW

Revised: 04/30/2014

FPCO which administers FERPA, will make available to parents and eligible students a 

complaint form that can be accessed by the internet or by calling FPCO to request a 

complaint form, then link of which can be emailed to them. The complaint form will be 

posted on FPCOs Web site. FPCO routinely responds to telephone and email inquiries 

from parents and eligible students, providing them with guidance and interpretation on 

FERPA. The guidance often includes information on how to file a complaint with FPCO. 

This new complaint form greatly reduces the burden on parents and eligible students of 

having to write down information on how to file a complaint with FPCO and draft a 

letter. 

4. Efforts to Identify Duplication.

The provisions do not duplicate any other Federal requirements. No other agency has this 

information.

5. Burden Minimization as Applied to Small Businesses.

This data collection is consistent with the Administration’s regulatory principles to 

minimize burden on small entities.

6. Consequences of Less Frequent Data Collection. 

Should these collections of information under FERPA be conducted less frequently, the 

requirements of the Act would not be carried out.

7. Special Circumstances Governing Data Collection.

These information collection requirements are consistent with the guidelines in 5 CFR

1320.5(d)(2).

8. Consultation Outside the Agency.

The Department will publish a 60 and 30 day Federal Register Notice. 

9. Payments or Gifts to Respondents.

The information collection’s respondents will not receive any payment or gift for 

submitting any information related to FERPA.
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ICRAS ICR ID and OMB Number: (2027) 1880-NEW

Revised: 04/30/2014

10. Assurance of Confidentiality.

Personally identifiable information collected in the FERPA complaint process is covered 

under FPCO’s records system, “Family Educational Rights and Privacy Act (FERPA) 

Record Systems.” (18-05-02).

11. Questions of Sensitive Nature.

The FERPA compliant process does not address nor call for questions of a sensitive 

nature. 

12. Annual Hour Burden for Respondents/Record Keepers

There are approximately 500 parents and eligible students who are expected, based on 

previous yearly records at the Department, to annually respond to this data collection. 

We estimate that an average of 1.0 hours (60 minutes) per response is required for this 

data collection. 

No. Complaints 500

 Burden Hours: x 1.0

Total Burden Hours = 500

There are approximately 4 caseworkers who will be expected to copy and process the 

complaint form.

GS 13 @ 51.19 X 30 minutes per response = 15 hours

15 hours X 500 responses = $7678.50 X 3 GS-13s @ = $23, 035.50

GS 07 @ 20.22 X 30 minutes per response = 6 hours

6 hours X 500 responses = $3,033

Total Costs = $26,068.50

13. Annual Cost Burden to Respondents.

The total for the capital and start-up cost components of both information collection 

requirements is zero. The information collection requirements under FERPA do not 

require the purchase of any capital equipment nor create any start-up costs. Computers 

and word processing software used to complete this information collection are part of the 

respondents’ customary and usual business or private practices, and therefore are not 

included.
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ICRAS ICR ID and OMB Number: (2027) 1880-NEW

Revised: 04/30/2014

The total for operation and maintenance for this information collection is zero. The 

information collection does not create costs associated with generating, maintaining, and 

disclosing or providing the information that is not already identified in question 12 of this 

supporting statement.

14. Estimated Annual Cost to the Federal Government. 

There will be no annual cost to the Federal Government.

15. Reasons for Changes to the Burden Hours Estimated. 

This is a new collection; there is a program increase of 52,637 burden hours for 

respondents and record keepers.

16. Collection of Information with Public Results. 

The results of the collection of information will not be published. 

17. Approval to Not Display Expiration Date. 

ED is not seeking this approval. 

18. Exception to Certification Statement.

ED is not requesting any exceptions to the “Certification for Paperwork Reduction Act 

Submissions.”