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ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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. I dentify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or auth orizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review ty

pe of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . I f 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 Pay ment Analy sts to review and process the institutional pay ment request for T itle 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 an y funds postsecondary institutions receive under the HEA are used solel y for the purposes specif ied 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 b y institutions in the TIV programs, the HEA amendments of 1992 signif

icantl y 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 T IV program funds. We are requesting an e xtension 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, b y 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 re ceived from the current collection.

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 T IV funds to the institution. The current collection is used for the i dentification of program funds for pay

ment, 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 hardcop y format with the pay ment 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 spec ificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. This information is not available from an y 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 independentl y owned and operated and is not dominant in its field; or (3) a small3

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 frequentl y, as well as an y technical or legal obstacles to reducing burden. If the collection is not conducted, students at these institutions will not receive the Title

IVprogram 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 quarterl y;

 requiring respondents to prepare a written respon se to a collection of information in fewer than 30 day s 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 y ears;

 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 classifi cation that has not been reviewed and approved b y 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 wi th the pledge, or that unnecessaril y i mpedes 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, onl y one HCM2 or Reimbursement request during an y 30 - day time period. This office onl y ac cepts originals of documentation. Documentation with the submission will not be returned. Therefore, the Department strongl y recommends that the institution maintain a copy of the4

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /2014 RIN Number: XXXX - XXXX (if applicable)

HCM2/Reimbursement submission. Federal Student Aid’s Department wide reco rd 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 Pay ment Records) Disposition: Dispose of 30 years after the end of the FY in which the final p ay ment is made. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 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 b y 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 an y), 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 th e Federal Register to allow for public comment. 8. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification .

No pay ment or gifts will be provided to the respondents. 9. Describe an y assurance of confidentialit y 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 in cluded on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the IC Data Form . A confidentiality statement with a legal citation that authorizes the pledge of co nfidentiality should be provided. 2 If the 2 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

– OMB5

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 make s no pl edge 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 Pay ment internal procedures provides information concerning Protection of Personally

I dentifiable Information for the institutions. 10. Provide additional justification for an y 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 infor mation is requested, and an y steps to be taken to obtain their consent. The Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of res pondents by affected public ty

pe (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 b urden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct spec ial survey s 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 widel y because of differences in activity , s ize, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, 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 ROCI S IC Burden Analy sis Table . (The table should at minimum include Respondent ty pes, IC activity , Respondent and Responses, Hours/Response, and Total Hours)  Prov ide 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)6

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 Pay ment, we averaged 60 schools reporting within a single ye ar and 1 school reporting for the Reimbursement Method of Pay ment. **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 $21607

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 s ys tem 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 widel y, agencies should present ranges of cost burdens and explain the reasons for the varian ce. 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 p ublic comment process and use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.  Generally , estimates should not include purchases of equipment or services, or portions ther eof, 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 :8

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 for Profit 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 for Profit 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 an y 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 materiall y changes a collection of information and generally are result of new statute or an age ncy action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretio n) , ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (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.9

ICRAS Tracking and OMB Number: (1453.05) 1845 - 0089 Revised: 0 8/12 /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 analy

tical 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 i nformation 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 certificatio n statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83 - 1.