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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Loan Cancellation in the Federal Perkins Loan Program

1. 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.

This is a request for the renewal of the OMB approval for the recordkeeping requirements 

contained in 34 CFR 674.53, 674.56, 674.57, 674.58 and 674.59. The information 

collections in these regulations are necessary to determine Federal Perkins Loan (Perkins 

Loan) Program borrower’s eligibility to receive program benefits and to prevent fraud 

and abuse of program funds.

Section 674.53 – Teacher cancellation – Federal Perkins, NDSL, and Defense loans.

This regulation identifies the requirements for teachers to qualify for cancellation 

benefits while performing: full-time teaching in an elementary or secondary

school serving low-income students; full-time teaching in special education or 

full-time teaching in fields of expertise as identified in regulation.

Section 674.56 – Employment cancellation – Federal Perkins, NDSL, and Defense loans.

This regulation identifies the categories of service for borrowers to qualify for 

cancellation benefits including: full-time employment as a nurse or medical 

technician; full-time employment in a public or private nonprofit child or family

service agency; service as a qualified professional provider of early intervention 

services; full-time employment as a firefighter to a local, State, or Federal fire 

department or fire district; full-time employment as a faculty member at a Tribal 

College or University; full-time employment as a librarian with a master’s degree; 

or full-time employment as a speech pathologist with a master’s degree.

Section 674.57 – Cancellation for law enforcement or corrections officer service –

Federal Perkins, NDSL, and Defense loans.

 

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Please limit pasted text to no longer than 3 paragraphs.
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

This regulation identifies the requirements for law enforcement or corrections 

officers to qualify for cancellation benefits for an eligible employing agency as 

identified in regulation.

Section 674.58 – Cancellation for service in an early childhood education program.

This regulation identifies the requirements for staff members in a Head Start 

program to qualify for cancellation benefits as identified in regulation.

Section 674.59 – Cancellation for military service.

This regulation identifies the requirements for borrowers who are members of the 

U.S. Army, Navy, Air Force, Marine Corps, or Coast Guard to qualify for 

cancellation benefits as identified in regulation.

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 requests for cancellation of Perkins Loans are received by the institution to 

determine the eligibility of the borrower and their loans for the cancellation being 

requested. The recordkeeping requirements are imposed to ensure accountability or 

program participants for proper program administration and to justify the payment of 

funds by the federal government. Not collecting the information described would likely

result in a loss of Federal money due to waste, fraud and abuse. 

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.

Schools conduct business with the Department of Education electronically and share 

information with the National Student Loan Data System (NSLDS) to verify accuracy of 

Perkins Loan records.

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.

A review of procedures indicates that the current requirements are minimal and 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 government jurisdiction, 
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

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 impacted by this 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.

Record keeping requirements are imposed to assure accountability of program 

participants for proper program administration and less frequent collections impair 

accountability of program participants.

7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, 

grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and reliable 

results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established in 

statute or regulation, that is not supported by disclosure and data security policies that are 

consistent with the pledge, or that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to protect 

the information’s confidentiality to the extent permitted by law.

The collection of this information will be conducted in a manner that is consistent with 

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, 
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

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.

This is the 30 day comment period for this collection package to solicit comments on the 

current burden assigned to this regulation. To date no comments have been received 

regarding this current information request.

9. 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 were provided to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

While there is no Federal instrument for borrowers to use to request these program 

benefits, the institution may require the borrower’s Social Security Number to process the 

cancellation request. The Perkins Loan promissory note signed by the borrower to 

receive the loan contains the Privacy Act Notice. In this notice, which also identifies 

categories of cancellations, the borrower is informed of the statutory authority for 

collecting the information requested. Although disclosure of the information is 

voluntary, the borrower is informed that in order to receive a Perkins Loan or benefit of 

the loan (cancellation, deferment, etc.) the information must be provided. The notice also 

identifies what information may be disclosed to whom and for what purpose the 

information may be disclosed.

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. 

 

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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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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

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 

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

14.

AFFECTED ENTITIES and BURDEN:

Section 674.53 – Teacher cancellation-Federal Perkins, NDSL and Defense loans.

We estimate that there are 4,808 borrowers eligible for this cancellation. We estimate the 

burden on each borrower for submission of documentation to obtain this cancellation will 

take .5 hours per borrower.

BORROWERS:

4,808 X .5 hours (30 minutes) = 2,404 hours

We estimate that each institution will have additional burden of .25 hours to process the 

cancellations per eligible borrower.
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

INSTITUTIONS:

Proprietary Institutions Responses:

337 (.07 X 4,808 borrowers) X .25 hours (15 minutes) = 84 hours

Private Institutions Responses:

2,740 (.57 X 4,808 borrowers) X .25 hours (15 minutes) = 685 hours

Public Institutions Responses:

1,731 (.36 X 4,808 borrowers) X .25 hours (15 minutes) = 433 hours

Total Burden on Institutions: 1,202 hours

Section 674.56 – Employment cancellation – Federal Perkins, NDSL and Defense loans.

We estimate that there are 7,216 borrowers eligible for this cancellation. We estimate the 

burden on each borrower for submission of documentation to obtain this cancellation will 

take .5 hours per borrower.

BORROWERS:

7,216 X .5 hours (30 minutes) = 3,608 hours

We estimate that each institution will have additional burden of .25 hours to process the 

cancellations per eligible borrower.

INSTITUTIONS:

Proprietary Institutions Responses:

505 (.07 X 7,216 borrowers) X .25 hours (15 minutes) = 126 hours

Private Institutions Responses:

4,113 (.57 X 7,216 borrowers) X .25 hours (15 minutes) = 1,028 hours

Public Institutions Responses:

2,598 (.36 X 7,216 borrowers) X .25 hours (15 minutes) = 650 hours

Total Burden on Institutions: 1,804 hours

Section 674.57 – Cancellation for law enforcement or corrections officer service.

We estimate that there are 809 borrowers eligible for this cancellation. We estimate the 

burden on each borrower for submission of documentation to obtain this cancellation will 

take .5 hours per borrower.
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

BORROWERS:

809 X .5 hours (30 minutes) = 405 hours

We estimate that each institution will have additional burden of .25 hours to process the 

cancellations per eligible borrower.

INSTITUTIONS:

Proprietary Institutions Responses:

57 (.07 X 809 borrowers) X .25 hours (15 minutes) = 14 hours

Private Institutions Responses:

461 (.57 X 809 borrowers) X .25 hours (15 minutes) = 115 hours

Public Institutions Responses:

291 (.36 X 809 borrowers) X .25 hours (15 minutes) = 73 hours

Total Burden on Institutions: 202 hours

Section 674.58 – Cancellation for service in a Head Start program. 

We estimate that there are 5,561 borrowers eligible for this cancellation. We estimate the 

burden on each borrower for submission of documentation to obtain this cancellation will 

take .5 hours per borrower.

BORROWERS:

5,561 X .5 hours (30 minutes) = 2,781 hours

We estimate that each institution will have additional burden of .25 hours to process the 

cancellations per eligible borrower.

INSTITUTIONS:

Proprietary Institutions Responses:

389 (.07 X 5,561 borrowers) X .25 hours (15 minutes) = 97 hours

Private Institutions Responses:

3,170 (.57 X 5,561 borrowers) X .25 hours (15 minutes) = 793 hours

Public Institutions Responses:

2,002 (.36 X 5,561 borrowers) X .25 hours (15 minutes) = 501 hours
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

Total Burden on Institutions: 1,391 hours

Section 674.59 – Cancellation for military service.

We estimate that over a five year period of submission required to receive 100% cancellation 

that there will be 43,117 borrowers eligible for this cancellation. We estimate the burden on 

each borrower for submission of documentation to obtain this cancellation will take .5 hours 

per borrower.

BORROWERS:

43,117 X .5 hours (30 minutes) = 21,559 hours

We estimate that each institution will have additional burden of .25 hours to process the 

cancellations per eligible borrower.

INSTITUTIONS:

Proprietary Institutions Responses:

3,018(.07 X 43,117 borrowers) X .25 hours (15 minutes) = 755 hours

Private Institutions Responses:

24,577 (.57 X 43,117 borrowers) X .25 hours (15 minutes) = 6,144 hours

Public Institutions Responses:

15,522 (.36 X 43,117 borrowers) X .25 hours (15 minutes) = 3,881 hours

Total Burden on Institutions: 10,780 hours

# of Respondents # of Responses #Hrs

Burden

BORROWERS 61,511 61,511 30,757

INSTITUTIONS 1,529 61,511 15,379

TOTAL 63,040 123,022 46,136

Changes to Affected Entities and Burden:

Current Inventory

 117,162 117,162 43,938

Revised Inventory

 63,040 123,022 46,136

Difference

 -54,122 +5,860 +2,198
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

Annual Cost of Burden to Respondents

No significant additional costs.

Previously the number of respondents was the same as the number of responses. This is 

inaccurate. For the 2010-2011 award year there were 1,529 institutions participating in the 

Perkins Loan program. This filing shows a decrease in respondents to correct this overreporting of institutional respondents.

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 : 

There are no start-up costs associated with these regulations.
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ICRAS Tracking and OMB Number: (1464) 1845-0100 v2 Revised: 1/28/2013

RIN Number: XXXX-XXXX (if applicable)

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 are no additional costs to the Federal government as a result of these regulations.

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).

The Department of Education is requesting an extension of this information collection. 

The regulations requiring this collection remain in place without change. There has been 

a slight increase in the estimated burden hours due to an anticipated increase in requests 

for the types of service performance cancellations identified in the regulations. 

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 the collection of information will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

The Department is not seeking this approval.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The Department is not requesting any exceptions to the “Certification for Paperwork 

Reduction Act Submissions” of OMB Form 83-I.