1

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) **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 cop y 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 section 1

. Specify the review t ype of the collectio n (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. Section 487(c) of the Higher Education Act (HEA) of 1965, as amended requires that the Secretary of Education prescribe regulations to ensure that an y funds postsecondary institutions receive under the HEA are used solel y 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 Title IV programs, the HEA amendments of 1992 significantl y increased ED’s gatekeeping responsibilities. In general, the statutory

provisions tightened the eligibility requirements for institutions participating in the student financial assistance programs authorized under Title IV of the HEA. In 1994, the S ecretary

amended the regulations governing institutional eligibility under the HEA in accordance with the statutory requirements. The Institutional Eligibility regulations govern the initial and continuing eligibility of postsecondary

educational institut ions participating in the student financial assistance program authorized b y Title IV of the HEA. Part H, Subpart 3, Section 498 of the HEA of 1965, as amended, gives the Secretary the responsibility

for determining qualifications of institutions of higher education to participate in programs under the HEA. To comply with this requirement Section 498(b) of the HEA specified that the Secretary

prepare and prescribe a single application form. The Department developed the Application for Approval to Parti cipate in the Federal Student Financial Aid Programs to comply with the statutory

requirements of collecting necessary information under the HEA. An institution must use this Application to apply for approval to be determined to be eligible and if the i nstitution wishes, to participate; to expand its eligibility ; or to continue to participate in the Title IV programs. An institution must also use the application to report certain required data as part of its recordkeeping requirements contained in the r egulations under 34 CFR Part 600 (Institutional Eligibility under the Higher Education Act of 1965, as amended).

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

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) The Department uses the information reported on the Application in its determination of whether an institution meets the statutory and regulatory

requirements. Listed below are the specific regulations that require an institution to apply to the Department of Education for:

 An eligibility

determination and if requested, certification to participate;  Continued eligibility

to participate ;  Reporting changes made to the institution, as required; and  Expansion of its current approval. Section 600.20
- Application procedures
- requires an institution that wishes to participate in any Title IV program, to apply for initial eligibility , as we ll as continued or expanded approval including new locations or new programs. Section 600.21

– Updating Application Information
- requires an institution to notify the Secretary of an y changes to certain information, including its name, address, etc. Section 600.31
- Change in ownership resulting in a change of control
- requires an institution that has undergone a change in ownership that results in a change in control to demonstrate to the Secretary that it meets the requirements of an eligible inst itution in order to continue to be eligible. The 1998 Amendments provided that the Secretary may continue the institution’s participation on a provisional basis provided that the institution under the new ownership submits a materially complete applicatio n that is received b y the Secretary no later than 10 business day s after the change occurs. In addition to the information above, the application is also the place where schools can report other information to us that it needs or wants us to know. For e xample, the Higher Education Act of 1965 (HEA), as amended, requires an institution of postsecondary education to file a disclosure report with the Secretary on January

31 or July

31 of each year, containing certain information about gifts received from or contracts entered into with foreign sources or about ownership or control of the institution by a foreign source (Section 1209, 20 U.S.C. 1145d). 2. Indicate how, by

whom, and for what purpose the information is to be used. Except for a new collectio n, indicate the actual use the agency has made of the information received from the current collection. The School Eligibility

Service Group, (the organization within the Department of Education, Federal Student Aid, responsible for providing integrated oversight to postsecondary schools) reviews and analy zes the information reported on the application and m akes a determination on the institution’s request. The School Participation Division’s (SPD) decision to approve an institution’s request for Title IV program eligibility onl y (in the case of an institution of higher education that does not plan to parti cipate in our Title IV programs, however, it wishes for its students to be eligible for in
- school deferments while in attendance), or Title IV eligibility

and participation is based not only on the information reported by the3

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) institution on the application , but also on other information in the team’s possession. SPD makes its decision using a case team approach to its work processes. This allows SPD to evaluate a school based on a total picture of integrated institutional information. SPD’s decision inc ludes determining that the institution:  Is designated an eligible institution;  Is certified or recertified to participate in Title IV programs;  Is approved, for Title IV purpose, to expand its current approval (new location or new programs, etc.);  Met it s reporting requirements and we have updated our records (changes to name or address, etc.); or  Is denied eligibility , certification or approval of its expansion for purposes of Title IV. 3. Describe whether, and to what extent, the collection of inform ation 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 colle ction. Also describe an y consideration given to using technology

to reduce burden. The data submitted b y an institution during the initial round of certification became part of the Postsecondary

Education Participants Sy stem (PEPS), the Department of E ducation's computerized information management s ys tem of institutional data. Subsequently , the School Eligibility

Service Group designed a computerized version of the Application. An institution accesses the Application using the Internet. Man y of the qu estions on the Application are pre
populated using information the institution submitted on its previous Application, which is stored in PEPS. Pre
- populating the answers to the questions reduces burden for the institution and alleviates the need for the i nstitution to enter a response to every question. Instead, the institution needs to review the pre
- populated information and if necessary , update it. (Note: Certain questions must be answered each time an institution submits a complete application.) On ce the institution has completed its updates to the Application, the updated application is submitted to the School Eligibility Service Group via the Internet. The institution receives immediate notification of receipt b y the Department. Once the Departm ent makes its decision to approve or to den y the Application, the information from the Application is migrated to PEPS electronically , thus reducing the Department’s burden for data entry as well as increasing the accuracy of the data in PEPS. The electr onic application has additional features such as:  Hot links to take the user from one area to another in one mouse click;  Skip features that skip questions or a section if it does not apply to the institution;  Edits that help the institution not miss a required question or enter the wrong t ype of information;  A Help section;  ED contacts, both phone numbers and e
- mail address. The e
- mail address is actually a hot link directly

to SPT or PEPS and allows an institution to submit its questions to the Department electronically ; and  A status page that tells the institution where the application is in SPT’s review process.4

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) Sy stem of Record Notice: 18
- 11
- 09
-- 64 FR 30171
- 30173, June 4, 1999 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information already available cannot be used or modified for use for the purposes described in Item 2 above. Institutions are not required to maintain duplicate records. The Application for Approval to Participate in the Federal Student Financial Aid Programs provides the initial contact of an institution seeking to participate in Federal programs administered by Federal Student Aid. A new institution will not have provided similar information to any other office in the Department. While a continuing institution may have provided similar information as part of the Integrated Postsecondary

Education Data Sy stem (IPEDS) survey , the Application information provided is not necessaril y the same. 5. If the collection of information impacts sm all businesses or other small entities, describe an y methods used to minimize burden. A small entit y 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 sm all 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 , count y, town, township, school district, or special district with a population of less than 50,000. The information collection does not impact small businesses or other small entities. 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. Section 498(g) of the HEA requires that the Department recertify all eligible institutions that wish to continue to participate in the Title IV programs. The maximum time period the Secretary may approve an institution is up to 6 years. The statute also provides that the Secretary may provisionally

certify new institutions, institutions that change ownership, and institutions with questionable financial responsibility and administrative capability

for a period of time from one to three years. The Department uses provisional approval as a tool to allow for increased monitoring of institutions with no track record and institutions with documented problems. If information w ere collected less frequentl y, ED would not be in compliance with the HEA and would not be using the tools Congress provided to improve gatekeeping capability
. Note that it is not necessary for an institution to submit a complete application to report ac tivities such as change in name or address, a change in level of course offering or a change in measurement of program length. Instead, with the Application, institutions need to update onl y the questions on the Application that are affected by the change . Thus, while the frequency with which institutions must report certain changes has not changed and cannot, because they are vital5

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) pieces of information relative to the institution's eligibility , the reporting burden for those actions is decreased signifi cantl y. If the collection is not conducted, a new institution would not be able to participate in Title IV programs, a currently approved institution would not be able to participate past its approved expiration date, meet the notification and recordkeep ing requirements or be able to expand its eligibility . Further, the Department would lose a valuable gatekeeping tool. 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 response 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 o f 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 re sults than can be generalized to the universe of study ;  requiring the use of a statistical data classification 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 with the pledge, or that unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or  requiring respondents to submit prop rietary 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. This collection of information does not meet an y of the special circumstances described above. 8. 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 age ncy 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 of6

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) information activity

is the same as in prior periods. There may be ci rcumstances that may preclude consultation in a specific situation. These circumstances should be explained. We will publish 60
- day

and 30
- day Federal Register notices to seek public comment. The Application has been widely accepted by

the community

an d has been in use in its current form since September of 1996. The current form was created after a focus group of industry professionals (redesign group) worked with the Department to address the higher education community ’s concerns about complexity , le ngth, and burden regarding the previous version of the Application. The goals of improving the clarit y, accuracy and simplicity of the Application while still allowing the Department to improve gatekeeping, have a more efficient process, receive more reli able information from the institution, and provide for institutional accountability , produced a valuable tool that asks clear questions that do not burden institutions. The Department holds a conference each F all devoted to the effective and efficient administration of the Title IV, HEA programs. The Application is one of the processes that are featured at these conferences. Responses received from school officials continue to be extremely positive. The feedback provided b y users indicates that the que stions in the Application are clear and that the process to complete the Application is simple. In addition, Department officials routinel y attend state, regional and professional association meetings and conferences. Ty picall y, the Department partic ipates in these forums as an opportunity

to receive feedback from the higher education communit y regarding its policies and procedures including the Application and the recertification process. The feedback continues to overwhelming approve the Applicatio n in part, due to the reduction of data collection burden. In addition to attending meetings and conferences, the Department also receives feedback from the community

via telephone calls and e
- mails. The Department has been responsive to these comments and suggestions from the community . We continued to make changes to improve the Application, which make it even easier to use. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees wi th meaningful justification
. None 10. Describe an y 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 Sy stems of Record Notice and the date a Privacy Impact Assessment was completed as indicated o n the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to 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

– OMB7

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. The Application includes a Privacy Act Notice that (1) informs the institution of the statutory authorit y for the information collection, (2) explains that disclosure of the information is voluntary , but if the institution chooses not to submit an Application for Approval to Participate in Federal Student Financial Aid Programs, the institution cannot be det ermined to be eligible or continued to be eligible for the Title IV, HEA programs, and (3) identifies the third parties to whom the information may be disclosed.
11. Provide additional justification for an y questions of a sensitive nature, such as sexua l behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y the agency considers the questions necessary , the specific uses to be made of the information, the explan ation to be given to persons from whom the information is requested, and an y steps to be taken to obtain their consent. This collection does not ask questions of a sensitive nature. 12. Provide estimates of the hour burden of the collection of informati on. The statement should:

 Indicate the number of respondents 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 tri bal governments) , frequency of response, annual hour burden, 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. Unle ss directed to do so, agencies should not conduct special 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 expecte d to vary widel y because of differences in activity , size, 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.  I f 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 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)8

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable)

activities should not be included here. Instead, this cost should be included in Item 14. 34 CFR Requirement Number of

Respondents 3 Number of

Responses/ Applications Reported Annuall y Hours Required

to Collect and Report Total Hours

600.20 Initial Applications

– Affected Entities For
- Profit Institutions 70 70 17 1 , 190 Not
- for
- Profit Institutions 13 13 17 221 Public Institutions 3 3 17 51 Sub
- total 86 86 17 1 , 462 600.20 Recertification

– Affected Entities For
- Profit Institutions 488 488 10 4,880 Not
- for
- Profit Institutions 455 455 10 4,550 Public Institutions 477 477 10 4,770 Sub
- total 1 , 420 1 , 420 10 14,200 600.20 Foreign Recert

– Affected Entities For
- Profit Institutions 2 2 15 30 Not
- for
- Profit Institutions 29 29 15 435 Public Institutions 137 137 15 2,055 Sub
- total 168 168 15 2 , 520 600.20 Expanded Eligibility

– Affected Entities For
- Profit 330 647 1 647
3 Many instituti ons report more than once a year, therefore a single respondent could be counted under several of the required regulatory reporting areas. As a result, the unduplicated number of respondents is a number smaller than the sum of the sub
- totals

– see below.9

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) 34 CFR Requirement Number of

Respondents 3 Number of

Responses/ Applications Reported Annuall y Hours Required

to Collect and Report Total Hours

Institutions Not
- for
- Profit Institutions 244 244 1 244 Public In stitutions 596 1 , 168 1 1 , 168 Sub
- total 1 , 170 2 , 056 1 2 , 05 9 600.21 Updating Eligibility

– Affected Entities For
- Profit Institutions 1 , 026 1 , 477 1 1 , 477 Not
- for
- Profit Institutions 696 1 , 002 1 1 , 002 Public Institutions 703 1 , 012 1 1 , 012 Sub
- total 2 , 425 3 , 491 1 3 , 491 600.31 Change in Ownership

– Affected Entities For
- Profit Institutions 53 53 10 530 Not
- for
- Profit Institutions 9 9 10 90 Public Institutions 0 0 10 0 Sub
- total 63 63 10 620 Total Responses 5,33 1 1 7,28 6

Total Unduplicated Respondents 4,983 2
Total Hour Burden of Collection Information 24,3 5210

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable)
600.20 Refers to applications submitted by institutions for initial approval, reinstatement, recertification and expansion of its current eligibility . This requirement has been broken down into four lines since it takes a new school longer to complete an initial application than one that is submitting a recertification application. As explained earlier, the electronic application is pre
- po pulated with information the Department previously received from the institution. Further, an institution applying for expansion of its current eligibility onl y needs to complete the portion of the application that applies to the expansion, so it takes muc h less time to complete that ty pe of application. 600.21 Refers to the requirement that institutions must update the Department regarding certain required information such as changes to the institution’s name or address. 600.31 Refers to applications submitted for change in ownership that result in the change of control.This burden information was estimated based on recent (FY 20 12 ) conversations with institutions that have submitted applications for these various purposes. Provide estimates of annualized cost to respondents for the hour burdens for collection of information, identifying and using appropriate wage rate categories . **600.20 Initial Applicant** Position Wage Rate

Category Cost Per

Hour Hours Expended Cost Burden Senior Administrator $200,956 $97 1 $97 Professional Staff $62,800 $30 16 $480 Total 17 $577 1 Many institutions respond more than once a year, therefore a single respondent could be counted under several of the required regulatory reporting areas. As a result, the unduplicated num ber of respondents is a number smaller than the sum of the sub
- totals. **600.20 Recertification** Position Wage Rate

Category Cost Per

Hour Hours Expended Cost Burden Senior Administrator $200,956 $97 1 $97 Professional Staff $62,800 $30 9 $270 Total 10 $367 **600.20 Recertification of Foreign Institution** 2 The unduplicated number of Respondents.11

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) Position Wage Rate

Category Cost Per

Hour Hours Expended Cost Burden Senior Administrator $200,956 $97 1 $97 Professional Staff $62,800 $30 14 $420 Total 15 $517 **600.20 Request to Expand Eligibility**  Position Wage Rate

Category Cost Per

Hour Hours Expended Cost Burden Senior Administrator $200,956 $97 .40 $39
Professional Staff $62,800 $30 .60 $ 18 Total 1 $57 **600.21 Update Changes** Position Wage Rate

Category Cost Per

Hour Hours Expended Cost Burden Senior Administrator $200,956 $97 .40 $39 Professional Staff $62,800 $30 .60 $ 18 Total 1 $57 **600.31 Change in Ownership** Position Wage Rate

Category Cost Per

Hour Hours Expended Cost Burden Senior Administrator $200,956 $97 1 $97 Professional Staff $62,800 $30 9 $270 Total 10 $367 

### Annualized	Cost	for	Collection	of	Information 34 CFR Requirement Number of Institutions

Reporting Annually4 Cost per Institution Total Burden 600.20 Initial 109 $577 $62,893 600.20 Recertification 1412 $367 $518,20412

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) 34 CFR Requirement Number of Institutions

Reporting Annually4 Cost per Institution Total Burden 600.20 Foreign Recert 87 $517 $44,979 600.20 Expand Eligibility 1,266 $57 $72,162 600.21 1,497 $57 $85,329 600.31 114 $367 $41,838 Total Annualized Cost per Application for Institutions $825,405
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 to tal 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 dis closing 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 wi ll 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 fa cilities.  If cost estimates are expected to vary widel y, 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 anal ys is associated with the rulemaking conta ining 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 mon etization of the hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested :13

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) There is no cost burden to respondents or record
- keepers resulting from the information collection other than shown in items 12 and 14. The total government expense for capital and start up costs for this Information Collection is zero. 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. REVIEWERS COSTS: Identifies the amount of time for a reviewer to examine the information submitted on the application and the supporting documentation. This information is then reported out to the team for a full decision on the institution’s application. 34 CFR Requirement Number of

Institutions Reporting Annually Hours

Required for ED Review Total Hours Average Hourly Wage Cost per CFR

Requirement
600.20 Initial 109 2 218 $34 $7,412 600.20 Recertification 1,412 2 2,824 $34 $96,016 600.20 Foreign Recert 87 3 261 $34 $8,874 600.20 Expand Eligibility 1 , 266 1 1 , 266 $34 $43,044 600.21 1 , 497 .5 749 $34 $25,466 600.31 114 2 228 $34 $7,752 ED Cost to review of the Application information $188,564 ED Cost to maintain sy stem and improve electronic Application: $450,000 Total Annualized Cost to the Federal government: $638,564 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 agency 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 discretion) , 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)
.14

ICRAS Tracking and OMB Number: (1393) 1845
- 0012 Revised: 8/28/2013 RIN Number: XXXX
- XXXX (if applicable) There have been no significant program changes and therefore the hours required for each application ty

pe have not changed. The ch ange in hours is due to a change in the number of applications projected. The net impact is an increase of 3,171 hours. This results from a decrease in Initial applications and Change in Ownership applications, while all other ty pes of applications are expected to increase. The decrease in new institutions and in the buying and selling of existing institutions is likely due to the current economic conditions in the United States. As for the increases, Recertification applications are submitted shortly before an institution’s current eligibility expires and can therefore be reasonabl y projected. The increase in applications for Expanded and Updated Eligibility

likely results from continued improvement in the understanding of the application process, mo re consistent compliance with our reporting requirements, and institutions being more responsive to economic changes resulting in more changes to locations and educational programs. 16. For collections of information whose results will be published, outli ne 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, publicati on dates, and other actions. Application 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 will display the expiration date for the OMB approval on the form.
18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. There are no exceptions to the certification statement.