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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Request for Title IV Reimbursement or Heightened Cash Monitoring 2 (HCM2)

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 collection of this information is needed in order for the Payment 

Analysts to review and process the institutional payment request for Title 

IV (TIV) funds. Section 487 (c) of the Higher Education Act (HEA) of 

1965 as amended requires that the Secretary prescribe regulations to 

ensure that any funds postsecondary institutions receive under the HEA 

are used solely for the purposes specified in and in accordance with the 

provision of the applicable programs. The concept of this federal 

gatekeeping has a long history, originating in 1952. However, as a result 

of abuses by institutions in the TIV programs, the HEA amendments of 

1992 significantly increased ED’s gatekeeping responsibilities.

Title 34: Part 668—Student Assistance General Provisions (see attached), 

Subpart K—Cash Management (§668.161) establishes the rules and 

procedures for a participating institution to request, maintain, disburse, 

and manage TIV program funds.

We are requesting an extension of the current collection with a small 

change made to the form due to the elimination of three reporting items. 

However, the average time to gather information and complete the form 

has not changed. 

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.

 

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Please limit pasted text to no longer than 3 paragraphs.
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

The School Eligibility Service Group (SESG), (which is the principal 

operating component within the Department of Education, Federal Student 

Aid) reviews and analyzes the information reported on the Form 270 

(Request for Title IV Reimbursement and Heightened Cash Monitoring 

(HCM2)) and makes the determination on the institution’s request. The 

information provided on the form is used to process and pay for TIV funds 

to the institution.

The current collection is used for the identification of 

program funds for payment, the period covered by the request for funds 

and cash on hand.

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 Form 270 submitted for OMB clearance can be completed and sent in 

electronic format if the institution has digital signature capability. We are 

estimating that approximately 20% of the institutions will have digital 

signature capability. If the institution does not have digital signatures in 

place, the form is completed electronically, printed and signed and sent in 

hardcopy format with the payment package for processing.

The use of this form electronically will reduce the institution’s burden 

because the Institution completes one form for all TIV programs for which 

funds are requested.

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.

This information is not available from any other system or source. The 

requirements avoid duplication.

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 
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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.

Small businesses/entities complete one form for all TIV programs for 

which funds are requested.

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 the collection is not conducted, students at these institutions will not receive the Title 

IV program funds for which they are eligible.

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.

Institutions can submit, and our office will accept and process, only one 

HCM2 or Reimbursement request during any 30-day time period. This 

office only accepts originals of documentation. Documentation with the 

submission will not be returned. Therefore, the Department strongly 

recommends that the institution maintain a copy of the 
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

HCM2/Reimbursement submission. Federal Student Aid’s Departmentwide record retention policy is located within the Department of 

Education’s Records Disposition Schedules (ED/RDS), Part 10. Part 10, 

15a (Annual Request for Funds and Payment Records) Disposition: 

Dispose of 30 years after the end of the FY in which the final payment is 

made.

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.

The Department has contact with the institutional officials completing the form 

but no indication of problems with the form has been noted. A 60 day and 30 day

notice will be published in the Federal Register to allow for public comment.

8. Explain any decision to provide any payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

No payment or gifts will be provided to the respondents.

9. 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 

 

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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 
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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.

An institution receives a letter when placed on Reimbursement or HCM2. 

Section III.A. of the enclosure to the letter in the Method of Payment 

internal procedures provides information concerning Protection of 

Personally Identifiable Information for the institutions.

10. 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 

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 

 

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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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

activities should not be included here. Instead, this cost should be included in Item 

14.

For the Number of Respondents Reporting Annually for HCM2 Method of 

Payment, we averaged 60 schools reporting within a single year and 1 school 

reporting for the Reimbursement Method of Payment.

Hour Burden of Collection

34 CFR 

Requirement

Number of 

Respondents 

Reporting 

Annually

Frequency 

of Response

Annual 

Reporting/Response

Hours 

Requir

ed to 

Collect 

and 

Report

Total 

Hours

668.162(d) Reimbursement Method of Payment

Business or other 

for-Profit

1 12 12 5 60

Not-For-Profit 

Institutions

0 0 0 0 0

668.162(e) Heightened Cash Monitoring 2 Method of Payment (HCM2)

Business or other 

for-Profit

60 12 720 5 3600

Not-for-Profit 

Institutions

0 0 0 0 0

TOTAL 3660

Wage Rate:

Position Wage Rate Cost Per Hour

Professional Staff 

(Financial Aid Director)

$74,787 $36

Annualized Cost for Collection of Information 

34 CFR 

Requirement

Number of 

Respondents 

Reporting 

Annually

Cost per 

Institution

Total Burden

668.162(d) Reimbursement Method of Payment

Business or other 1 $2160 $2160
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

for-Profit

Not-For-Profit 

Institutions

0 0 0

668.162(e) Heightened Cash Monitoring Method of Payment (HCM2)

Business or other 

for-Profit

60 $131,760 $131,760

Not-For-Profit 

Institutions

0 0 0

TOTAL Hour Burden of Collection Information $133,920

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 : 
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

There is no cost burden to respondents or recordkeepers resulting from the information 

collection other than shown in items 12 and 14.

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.

34 CFR 

Requirement

Number of 

Respondents 

Reporting 

Annually

Hours 

Required 

for ED 

Review

Total Hours Average 

Hourly 

Wage

Cost per 

CFR 

Requirement

668.162(d) Reimbursement Method of Payment

Business or 

other forProfit

1 6 6 $40 $240

Not-For-Profit 

Institutions

0 0 0 0 0

668.162(e) Heightened Cash Monitoring Method of 

Payment (HCM2)

Business or 

other forProfit

60 7 420 $40 $16,800

Not-For-Profit 

Institutions

0 0 0 0 0

TOTAL Cost for ED review of the Payment Submission $17,040

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).

We are requesting an extension of the current burden assessment without change. The 

information collected on the form and number of users has remained stable.
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ICRAS Tracking and OMB Number: (1453.05) 1845-0089 Revised: 08/12/2014

RIN Number: XXXX-XXXX (if applicable)

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.

This information is not expected to 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.