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OMB Number: (2014) 1845-NEW2 v.1 Revised: 3/10/14

RIN Number: 1840-AD15 

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

GAINFUL EMPLOYMENT APPEALS FOR DEBT TO EARNINGS (D/E) RATES

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.

The Secretary proposes to amend the Student Assistance General Provisions by adding 

Subpart Q to Part 668, to establish measures for determining whether certain 

postsecondary educational programs lead to gainful employment in recognized 

occupations, and the conditions under which these educational programs remain eligible 

for student financial assistance programs authorized under Title IV of the Higher 

Education Act of 1965, as amended (HEA).

This will be a new collection and includes proposed §668.406 – Appeals for D/E rates.

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.

The proposed regulations would add new §668.406 which would provide an institution 

the opportunity to make an alternate earnings appeal, or in the case where an institution 

has GE programs with few borrowers, could make a low borrower rate appeal. An 

institution could appeal a GE program’s final D/E rates in any year in which the program 

is failing the D/E rates. However, to account for the addition of the zone, and the related 

student warning requirements, the proposed regulations would also permit an institution 

to make an appeal in any year in which the program’s final D/E rates are in the zone for 

that year.

In submitting an alternate earnings appeal under the proposed regulations, an institution 

would seek to demonstrate that the earnings of students who completed the GE program 

are sufficient to pass the D/E rates measure. 

 

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The institution would base its appeal on alternate earnings evidence from a survey

conducted in accordance with requirements established by NCES (or it could use data 

from a State-sponsored data system). The Secretary would publish in the Federal

Register the NCES survey protocols and Earnings Survey Form. Under the proposed 

regulations, the institution would certify that the survey was conducted in accordance 

with the requirements established by NCES and submit an examination–level attestation 

engagement report prepared by an independent public accountant or independent 

governmental auditor, as appropriate. 

The information provided on the proposed Alternative Earnings Survey Form would be 

provided by an institution to the Department for the purpose of appealing its most recent 

final D/E rate by proving the difference between the mean or median annual earnings the 

Secretary obtained from SSA and the mean or median annual earnings derived from an 

institutional survey is sufficient to warrant revisions to the final D/E rates. 

For a program that is failing or in the zone under the D/E rates measure, the proposed 

regulations allow an institution to make a showing of mitigating circumstances based on 

a program borrowing rate of less than 50 percent for all individuals (both those who 

received title IV, HEA program funds, and those who did not) who completed the 

program during the applicable cohort period not having to assume any debt to enroll in 

the program. 

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.

A survey form and survey protocols are under development through NCES. We 

anticipate a proposed form would be downloadable from the Department’s web site.

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.

The current requirements avoid duplication. There is no similar information available 

that can be used or modified for this purpose at this time.

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 affected by this information collection.
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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.

Absent this proposed data collection, the gainful employment program would become 

ineligible based on its final D/E rates. 

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

 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 collection of this information will continue to be conducted in a manner that is 

consistent with the guidelines in 5 CFR 1320.6.

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 
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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.

The proposed regulations were developed through the Negotiated Rulemaking process 

where the public provided its input and in consultation with schools, and other affected 

entities. The comment period for the information collection package will run 

concurrently with the Notice of Proposed Rulemaking.

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.

The Department makes no pledge of confidentiality regarding the data.

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 

 

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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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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.

Section 668.406(b) –Survey requirements.

The proposed regulations would provide an institution the opportunity to make an 

alternate earnings appeal under §668.406(b). An institution could appeal a GE program’s 

final D/E rates in any year in which the program is failing the D/E rates. However, to 

account for the addition of the zone, and the related student warning requirements, the 

proposed regulations would also permit an institution to make an appeal in any year in 

which the program’s final D/E rates are in the zone for that year. For example, a GE 

program that is failing the D/E rates measure for two consecutive award years (Year 1 

and Year 2) is in jeopardy of becoming ineligible for the subsequent award year (Year 3) 

if the program fails the D/E rates measure in Year 3. This GE program could submit an 

alternate earnings appeal of the Year 2 final D/E rates. As another example, a GE 

program that is in the zone for three consecutive award years (Year 1, Year 2, and Year 

3) is in jeopardy of becoming ineligible for the subsequent award year (Year 4) if the 

program does not pass the D/E rates measure in Year 4. This GE program could submit 

an alternate earnings appeal of the Year 3 final D/E rates. 

In submitting an alternate earnings appeal under the proposed regulations, an institution 

would seek to demonstrate that the earnings of students who completed the GE program 

in the two-year period are sufficient to pass the D/E rates measure. The institution would 

base its appeal on alternate earnings evidence from a survey conducted in accordance 

with requirements established by NCES or from a State-sponsored data system. 

The Secretary would publish in the Federal Register the NCES survey protocols and 

Earnings Survey Form. Under the proposed regulations, the institution would certify that 

the survey was conducted in accordance with the requirements established by NCES and 

submit an examination–level attestation engagement report prepared by an independent 
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public accountant or independent governmental auditor. The proposed regulation would 

require that the attestation be conducted in accordance with the attestation standards 

contained in the Government Accountability Office’s Government Auditing Standards 

promulgated by the Comptroller General of the United States (available at 

www.gao.gov/yellowbook/overview), and with procedures for attestations contained in 

guides developed by and available from the Department’s Office of Inspector General. 

We estimate that for-profit institutions would have 1,364 gainful employment programs 

in the zone and that 910 programs would be failing for a total of 2,274 programs. We 

expect that most institutions would determine that SSA data reflect accurately the 

earnings of students and would therefore not elect to conduct the survey. Accordingly, 

we estimate that for-profit institutions would submit alternate earnings appeals under the 

survey appeal option for 10 percent of those programs, which would equal 227 appeals 

annually. We estimate that conducting the survey, providing the institutional 

certification, and obtaining the examination-level attestation engagement report would 

total, on average 100 hours of increased burden, therefore burden would increase 22,700

hours (227 appeals times 100 hours of burden per appeal) under OMB Control Number 

1845-NEW2. 

We estimate that private-non-profit institutions would have 12 gainful employment 

programs in the zone and that 34 programs would be failing for a total of 46 programs. 

We expect that most institutions would determine that SSA data reflect accurately the 

earnings of students and would therefore not elect to conduct the survey. Accordingly, 

we estimate that private-non-profit institutions would submit alternate earnings appeals 

under the survey appeal option for 10 percent of those programs, which would equal 5

appeals annually. We estimate that conducting the survey, providing the institutional 

certification, and obtaining the examination-level attestation engagement report would 

total, on average. 100 hours of increased burden, therefore burden would increase 500

hours (5 appeals times 100 hours of burden per appeal) under OMB Control Number 

1845-NEW2.

We estimate that public institutions would have 7 gainful employment programs in the 

zone and that 55 programs would be failing for a total of 62 programs. We expect that 

most institutions would determine that SSA data reflect accurately the earnings of 

students and would therefore not elect to conduct the survey. Accordingly, we estimate 

that public institutions would submit alternate earnings appeals under the survey appeal 

option for 10 percent of those programs, which would equal 6 appeals annually. We 

estimate that conducting the survey, providing the institutional certification, and 

obtaining the examination-level attestation engagement report would total, on average, 

100 hours of increased burden, therefore burden would increase 600 hours (6 appeals 

times 100 hours of burden per appeal) under OMB Control Number 1845-NEW2. 

Collectively, the projected burden associated with conducting an alternative earnings 

survey would increase burden by 23,800 hours under OMB Control Number 1845-

NEW2.
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OMB Number: (2014) 1845-NEW2 v.1 Revised: 3/10/14

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Section 688.406(b) - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

238 238 100 23,800

Section 668.406(c) –State-sponsored data system requirements.

We estimate that there would be 1,364 failing GE programs at for-profit 

institutions and 910 programs in the zone, for a total of 2,274 programs. We expect that 

most institutions would determine that SSA data reflect accurately the earnings of 

students who completed a program and would therefore not elect to submit earnings data 

from a State-sponsored system. Accordingly, we estimate that in 10 percent of those 

cases, institutions would obtain earnings data from a State-sponsored system, resulting in 

approximately 227 appeals. We estimate that, on average each appeal would take 20 

hours, including execution of an agreement for data sharing and privacy protection under 

the Family Educational Rights and Privacy Act (20 U.S.C 1232g) (FERPA) between the 

institution and the State agency, preparing the list(s), submitting the list(s) to the 

appropriate State agency, reviewing the results, calculating the proposed revised D/E 

rates, and submitting those results to the Secretary. Therefore, burden would increase by

4,540 hours under OMB Control Number 1845-NEW2.

We estimate that there would be 34 failing GE programs at private non-profit 

institutions and 12 programs in the zone, for a total of 46 programs. We expect that most 

institutions would determine that SSA data reflect accurately the earnings of students 

who completed a program and would therefore not elect to submit earnings data from a 

State-sponsored system. Accordingly, we estimate that in 10 percent of those cases, 

institutions would obtain earnings data from a State-sponsored system, resulting in 5 

appeals. We estimate that, on average each appeal would take 20 hours, including 

execution of an agreement for data sharing and privacy protection under FERPA between 

the institution and the State agency, preparing the list(s), submitting the list(s) to the 

appropriate State agency, reviewing the results, calculating the proposed revised D/E 

rates, and submitting those results to the Secretary. Therefore burden would increase by 

100 hours under OMB Control Number 1845-NEW2. 

We estimate that there would be 55 failing GE programs at public institutions and 

7 programs in the zone, for a total of 62 programs. We expect that most institutions 

would determine that SSA data reflect accurately the earnings of students who completed 

a program and would therefore not elect to submit earnings data from a State-sponsored 

system. Accordingly, we estimate that in 10 percent of those cases institutions would 

obtain earnings data from a State-sponsored system, resulting in approximately 6 appeals. 

We estimate that, on average each appeal would take 20 hours, including execution of an 

agreement for data sharing and privacy protection under FERPA between the institution 

and the State agency, preparing the list(s), submitting the list(s) to the appropriate State 

agency, reviewing the results, calculating the proposed revised D/E rates, and submitting 

those results to the Secretary. Therefore, burden would increase by 120 hours under 

OMB Control Number 1845-NEW2. 
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Collectively, burden would increase by 4,760 hours under OMB Control Number 

1845-NEW2.

Section 688.406(c) - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

238 238 20 4,760

Section 668.406(d) – Low borrowing rate requirements:

We estimate that 2 percent of the total 2,274 programs at for profit institutions 

(910 zone programs plus 1,364 failing programs) or 45 programs at for profit institutions 

would submit a low borrowing rate appeal and that generally this would be an automated 

process, however, there would be some situations, probably at a small institution where 

the process could be a manual process and therefore we estimate the average amount of 

time to collect the data, compile and submit the low borrower rate appeal would on 

average be 5 hours per appeal. The estimated burden would be 225 hours (45 appeals 

times 5 hours per appeal) under OMB Control Number 1845-NEW2.

We estimate that 5 percent of the total 46 programs at private non-profit 

institutions (12 zone programs plus 34 failing programs) or 2 programs at for private nonprofit institutions would submit a low borrowing rate appeal and that generally this would 

be an automated process, however, there would be some situations, probably at a small 

institution where the process could be a manual process and therefore we estimate the 

average amount of time to collect the data, compile and submit the low borrower rate 

appeal would on average be 5 hours per appeal. The estimated burden would be 10 hours 

(2 appeals times 5 hours per appeal) under OMB Control Number 1845-NEW2.

We estimate that 50 percent of the total 62 programs at public institutions (7 zone 

programs plus 55 failing programs) or 31 programs at public institutions would submit a 

low borrowing rate appeal and that generally this would be an automated process, 

however, there would be some situations, probably at a small institution where the 

process could be a manual process and therefore we estimate the average amount of time 

to collect the data, compile and submit the low borrower rate appeal would on average be 

5 hours per appeal. The estimated burden would be 155 hours (45 appeals times 5 hours 

per appeal) under OMB Control Number 1845-NEW2.

Section 688.406(d) - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

78 78 5 390

Section 668.406(e) – Alternate appeal procedures.
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We estimated above that for-profit institutions would have 227 alternate earnings 

survey appeals annually, plus 227 State-sponsored data system appeals, plus 45 low 

borrower rate appeals for a total of 499 appeals. We estimate that completing and 

submitting a notice of intent to use survey alternate earnings data, State data increases 

burden, or a low borrower rate appeal on average, by 0.25 hours per submission or 125

hours under OMB Control 1845-NEW2. 

We estimated above that private non-profit institutions would have 5 alternative 

survey appeals annually, plus 5 State-sponsored data system appeals, and 2 low 

borrowing rate appeals for a total of 12 appeals. We estimate that completing and 

submitting a notice of intent to use survey alternate earnings data, State data, or a low 

borrowing rate appeal increases burden, on average, by 0.25 hours per submission or 3 

hours under OMB Control 1845-NEW2. 

We estimated above that public institutions would have 6 alternative survey 

appeals annually plus 6 State-sponsored data system appeals, plus 31 low borrower rate 

appeals for a total of 43 appeals. We estimate that completing and submitting a notice of 

intent to use survey alternate earnings data, State data, or make a low borrowing rate 

appeal increases burden, on average, by 0.25 hours per submission or 11 hours under 

OMB Control 1845-NEW2. 

Collectively, the projected burden associated with completing and submitting a 

notice of intent would increase burden by 120 hours under OMB Control Number 1845-

NEW2.

Section 688.406(e) - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 554 554 .25 139

SUMMARY:

Currently Approved Numbers:

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

New Burden:

Section 688.406 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 1,108 1,108 29,089

Revised Numbers Requested:

 # of Respondents # of Responses Hours/Response Burden Hours

 1,108 1,108 29,089 
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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 

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 : 

Discussions with institutional representatives related to estimated costs for the surveys or 

use of State sponsored data systems would be conducted after the NPRM is published and 

prior to the final regulation’s publication to inform the cost estimate.

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.
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The cost to the federal government will be determined following the discussions above 

that occur after the NPRM and prior to the final regulation’s publication.

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).

This is a new collection due to the changes to burden under proposed §668.406 that are a 

result of the addition of Subpart Q of Part 668. The program changes are due to agency

discretion upon completion of Negotiated Rulemaking sessions.

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 this collection of information will not be published.

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 this approval.

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 for Paperwork 

Reduction Act Submissions” of OMB Form 83-1.