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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

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.

Sections 428(b)(1)(M) [20 U.S.C. 1078(b)(1)(M)], 455(f)(2) [20 U.S.C. 1087e(f)(2)], and 464(c)(2)(A) [20 

U.S.C. 1087dd(c)(2)(A)] of the Higher Education Act of 1965, as amended, (the HEA) provide that a 

borrower under the Federal Family Education Loan (FFEL) Program, the William D. Ford Federal Direct 

Loan (Direct Loan) Program, and the Federal Perkins (Perkins) Loan Program may temporarily defer 

payments on his or her eligible loans while serving on active duty during a war or other military 

operation or national emergency, and for an additional 180-day period following the conclusion of the 

borrower’s qualifying military service. This deferment is referred to as a “military service deferment.” 

Section 493D of the HEA [20 U.S.C. 1098f] provides that a FFEL, Direct Loan, or Perkins Loan program 

borrower who (1) is a member of the National Guard or other reserve component of the U.S. Armed 

Forces or a retired member of the U.S. Armed Forces and (2) is called or ordered to active duty while 

enrolled at an eligible school or within six months of having been enrolled may defer repayment of his 

or her eligible loans for up to 13 months following the conclusion of the borrower’s active duty military 

service, or until the borrower returns to enrolled student status, whichever occurs earlier. This 

deferment is known as a “post-active duty student deferment.”

The regulations that govern the military service deferment and the post-active duty student deferment 

are in 34 CFR 682.210(t) and (u) [for the FFEL Program], 34 CFR 685.204(e) and (f) [for the Direct Loan 

Program], and 34 CFR 674.34(h) and (i) [for the Perkins Loan Program]. These regulations require a 

borrower to request a deferment and to provide information to the loan holder establishing the 

borrower’s eligibility for the deferment.

Section 428(d) clarifies that the Servicemember Civil Relief Act (SCRA) is applicable to loans made under 

the FFEL and Direct Loan Programs. Borrowers with such loans are eligible to have the interest rate on 

their loans limited to 6% during periods of eligible military service if they received those loans prior to 

entering the eligible military service.

 

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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

The regulations that cover the SCRA are in 34 CFR 682.202 and 685.202. These regulations require the 

borrower to request the interest rate limitation under the SCRA and provide information to the loan 

holder establishing the borrower’s eligibility for the benefit.

The U.S. Department of Education (ED) is requesting a revision of the collection currently approved 

under OMB No. 1845-0080. ED is making no major changes to the military deferment form; rather, it is 

proposing a number of linguistic changes to be more consistent with other approved loan servicing 

forms. ED is proposing the creation of an optional form that borrowers would use to request that their 

interest rate be limited to 6% during periods of eligible military service under the Servicememebrs Civil 

Relief Act.

A justification for the data elements on the deferment request and SCRA form is included at the end of 

this supporting statement.

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 currently approved deferment request serves as the means by which a borrower submits a request 

for a military service deferment to his or her loan holder and provides the loan holder with the 

information needed to establish that the borrower meets the eligibility requirements for the deferment. 

The revised deferment request form will continue to be used for this purpose, and will also serve as the 

means by which a borrower requests a post-active duty student deferment, and by which ED identifies 

Direct Loan borrowers who qualify for the no accrual of interest benefit for active duty service 

members. 

The SCRA request will serve as the means by which a borrower submits a request for their loan holder to 

limit the interest rate on their FFEL or Direct Loan to 6% under the SCRA.

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.

The collection of information does not involve the use of technological processes such as electronic 

submissions. A borrower must establish his or her eligibility for the deferment either by obtaining a 

certification from a military official on the deferment request form, or by providing the loan holder with 

a copy of the borrower’s military orders. Because of the requirement for a third-party certification or 

submission of additional documentation, most borrowers prefer to use the United States Postal Service 

or an alternative mail delivery service currently provide the only practical means for a borrower to 

submit a military service deferment / post-active duty student deferment request. 

The collection of information does not involve the use of technological processes such as electronic 

submissions. A borrower must establish his or her eligibility for the SCRA limitation by providing the 

loan holder with a copy of the borrower’s military orders. Because of the requirement for submission of 

additional documentation, most borrowers prefer to use the United States Postal Service or an 
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

alternative mail delivery service currently provide the only practical means for a borrower to submit an 

SCRA request.

At the option of the loan holder or loan servicer, however, both forms could be adapted for online use 

by mapping the data elements to a web form and provided for the scanning and uploading of the thirdparty certification or supporting documentation.

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 similar information already available from other sources that can be used for the purposes 

described in Item 2.

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.

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.

If a borrower did not complete either request, there would be no means by which the loan holder could 

determine the borrower’s eligibility for a military service deferment or post-active duty student 

deferment, the borrower’s eligibility for the Direct Loan Program’s no accrual of interest benefit for 

active duty service members, or the borrower’s eligibility for the SCRA interest rate limitation. 

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;
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

 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 be conducted in a manner that does not involve any of the 

guidelines in 5 CFR 1320.5(d)(2).

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.

We considered recommendations from the financial aid community when developing the currently 

approved military deferment request form, and when drafting the revised form that will be posted for 

review during the initial 60-day public comment period. The Department will consider all comments 

received during the 60-day comment period, make changes, and then give the public another, 30-day 

comment period to suggest further changes.

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 respondents.
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

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 deferment and SCRA request form includes a Privacy Act Notice that (1) informs the respondent of 

the statutory authority for the information collection; (2) explains that disclosure of the requested 

information is voluntary, but is required in order for the deferment request to be processed; and (3) 

identifies the third parties to whom the information may be disclosed, and explains the circumstances 

under which such disclosures may occur.

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.

This information collection does not request any sensitive information. 

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.

 

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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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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

 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.

The total estimated annual reporting hour burden for this information collection is approximately 8,000 

hours. The burden estimate was calculated as follows:

Estimated annual number of respondents: 16,000

Number of responses per borrower: x 1

Hours per response: x 0.5 (30 minutes)

Annual hour burden: 8,000 hours

Estimated annual number of respondents: 4,708

Number of responses per borrower: x 1

Hours per response: x 0.25 (15 minutes)

Annual hour burden: 1,177 hours

The total estimated cost burden for this collection is $7,525.68. This estimate was calculated by 

multiplying the estimated number of respondents by the current cost of postage required to return the 

deferment request form ($0.46). 

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 
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

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

There are no startup costs to respondents.

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 is no significant cost to the federal government associated with military deferment and SCRA 

requests submitted by FFEL, Direct Loan, and Perkins borrowers, since FFEL Program loan holders, Direct 

Loan servicers, and Perkins schools distribute the form, collect the information, and process the 

deferment requests.

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).
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

ED is not reporting any changes in the burden hour estimate for the military deferment form, though 

the burden associated with the collection, as a whole, is increasing as a result of the creation of the 

SCRA request form, which is new.

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 information collection 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.

Justification of Data Elements

Military Deferment Request

Data Element Justification

Section 1

Social Security Number Used for borrower identification.

Name Used for borrower identification.

Address

Used as the borrower’s official address to which 

correspondence related to the deferment is sent

City, State, Zip Same as “Address”.

Telephone - Home Used to contact the borrower if further information or 

clarification of responses is required.

Telephone - Other Used to contact the borrower if further information or 

clarification of responses is required.

E-mail (optional) Used to contact the borrower if further information or 

clarification of responses is required.
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

Section 2

(A) Check box for military service deferment. Collects the borrower’s request for the military service 

deferment. 

(B) Check box for the post-active duty student 

deferment.

Collects the borrower’s request for the post-active duty 

student deferment.

Section 3

Signature of Borrower or Borrower’s Representative 

and Date

Used to certify the validity of the information provided 

by the borrower. (For the military service deferment, 

the borrower’s designee may sign the form if the 

borrower has been deployed on a military operation 

and is not readily available to complete the deferment 

request.)

Name of Representative (if applicable) and Relationship 

to Borrower

Used for identification of the individual who is signing 

the deferment request on behalf of the borrower.

Address of Representative

In the absence of the borrower, used as the official 

address to which correspondence related to the 

deferment is sent.

Telephone Number of Representative

In the absence of the borrower, used to contact the 

borrower’s representative if further information or 

clarification of responses is required.

Section 4

(1) and (2). Check boxes to indicate type of military 

service.

Used to confirm that the borrower’s type of military 

service meets the eligibility requirements for the 

military service deferment.

(3) Check box to indicate whether the borrower served 

in an area of hostilities in which service qualifies for 

special pay.

Used to identify borrowers who qualify for the Direct 

Loan Program’s no accrual of interest benefit for active 

duty service members.

Period of the borrower’s military service Used to determine the deferment period.

Name of Military Branch or National Guard Used to identify the type of military service that is the 

basis for the borrower’s deferment request.

Address Used to contact certifying official if additional 

information or clarification is needed.

City, State, Zip Same as “Address”.

Name/Title of Authorized Official Used to identify the individual who is certifying the 

borrower’s eligibility for the deferment.

Telephone Same as “Address”.

Authorized Official's Signature and Date Used to certify the borrower’s eligibility for the 

deferment.
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 4/10/2013

Justification of Data Elements

SCRA Request

Data Element Justification

Section 1

Social Security Number Used for borrower identification.

Name Used for borrower identification.

Address

Used as the borrower’s official address to which 

correspondence related to the deferment is sent

City, State, Zip Same as “Address”.

Telephone - Home Used to contact the borrower if further information or 

clarification of responses is required.

Telephone - Other Used to contact the borrower if further information or 

clarification of responses is required.

E-mail (optional) Used to contact the borrower if further information or 

clarification of responses is required.

Section 2

Item 1, check the box that corresponds to your 

qualifying military service.

Collects the type of military service the borrowers is 

performing so that the borrower’s eligibility can be 

evaluated. Guides the borrower’s understanding of the 

eligibility criteria for the SCRA limitation.

Item 2, confirm that the borrower’s debts were 

incurred prior to the date of the borrower’s eligible 

military service.

Guides the borrower’s understanding of the eligibility 

criteria for the SCRA limitation.

Section 3

Signature of Borrower and Date Used to certify the validity of the information provided 

by the borrower.