ICRAS 2015 1 845
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– Affected Public

– State, Local or Tribal Governments 2 / 3 /201 4

The Secretary proposed to amend Student Assistance General Provisions by adding Subpart R to 34 CFR Part 668. The program cohort default rate is a measure the Department uses to determine the eligibility of a GE program under Subpart R of 34 CFR part. Th is subpart describes how program cohort default rates (pCDR) are calculated, some of the consequences of pCDRs, and how institutions may request changes to their pCDRs or appeal the consequences. Under this subpart, the institution submits a “challenge” a fter it receives its draft program cohort default rate, and the institution requests an “adjustment” or “appeal” after its official program cohort default rate is published.
Section 668.504(b)

– Draft cohort default rates and your ability to challenge b efore official program cohort default rates are issued, incorrect data challenges. Under proposed 668.504(b), the institution may challenge the accuracy of the data included on the Loan Record Detail Report (LRDR) by sending an incorrect data challenge to the relevant data manager(s) within 45 days of receipt of the LRDR from the Department. The challenge would include a description of the information in the LRDR that the institution believes is incorrect along with supporting documentation. Based upon FY 2011 submissions, there were 353 institutional CDR challenges for incorrect data of a total of 510 challenges, requests for adjustments, and appeals, a 69 percent submission rate. Therefore 69 percent of the projected 1,863 challenges, adjustments, and ap peals, or 1,285, are projected to be challenges for incorrect data. We estimate that, out of the likely 1,285 submissions, 64 (5 percent) would be from public institutions. We estimate that the average institutional staff time needed to review a GE pro gram’s LRDR for each of these 64 programs and to gather and prepare the challenges would be 4 hours (1.5 hours for list review and 2.5 hours for documentation submission). This would increase burden by 256 hours.

Section 668.509
- Uncorrected data adjustments. An institution may request an uncorrected data adjustment for the most recent cohort of borrowers used to calculate a GE program’s most recent official pCDR, if in response to the institution’s incorrect data challenge, a data manager agreed to chan ge data but the changes were not reflected in the official pCDR. Based upon FY 2011 submissions, there were 116 uncorrected data adjustments of the total 510 challenges, requests for adjustments, and appeals. Therefore, 23 percent of the projected 943 cha llenges, adjustments, and appeals (based on possible loss of eligibility) or 217 are projected to be uncorrected data adjustments. We estimate that the average institutional staff time needed is 1 hour for list review and 0.5 hours for documentation submi ssion, for a total of 1.5 hours. We estimate that 11 (5 percent) of the 217 projected uncorrected data adjustments would be from public institutions. Therefore, burden would increase at public institutions by 17 hours (11 adjustments times 1.5 hours) unde r OMB Control Number 1845
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– State, Local or Tribal Governments 2 / 3 /201 4

Section 668.510

– New data adjustments. An institution could request a new data adjustment for the most recent cohort of borrowers used to calculate the most recent official pCDR for a GE program, if a comparison of the L RDR for the draft rates and the LRDR for the official rates show that data have been newly included, excluded, or otherwise changed and the errors are confirmed by the data manager. Based upon FY 2011 submissions, there were 12 new data adjustments of the total 510 challenges, requests for adjustments, and appeals. Therefore, 2 percent of the projected 943 challenges, adjustments, and appeals (based on possible sanction) or 19 are projected to be new data adjustments. We estimate that the average institut ional staff time needed is 3 hours for list review and 1 hour for documentation submission, for a total of 4 hours. We estimate that 1 (5 percent) of the 19 projected new data adjustments would be from public institutions. Therefore, burden would increa se at public institutions by 4 hours under (1 adjustment times 4 hours) OMB Control Number 1845
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Section 668.512 Loan Servicing appeals. An institution could appeal the calculation of a pCDR on the basis of improper loan servicing or collection only if the borrower did not make a payment on the loan and the institution can prove that the servicer failed to perform required loan servicing or collections activities. Based upon FY 2011 submissions, there were 19 loan servicing appeals of the total 510 c hallenges, requests for adjustments, and appeals. Therefore, 4 percent or 38 of the projected 943 challenges, adjustments, and appeals are projected to be loan servicing appeals. We estimate that, on average, to gather, analyze, and submit the necessary documentation, each appeal would take 3 hours. We estimate that 2 (5 percent) of the 38 projected loan servicing appeals would be from public institutions. Therefore, burden would increase at public institutions by 6 hours (2 servicing appeals times 3 hours) under OMB Control Number 1845
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Section 668.513
- Economically disadvantaged appeals. An institution could appeal a notice of a sanction under §668.410 or a notice of a second successive official pCDR that is equal to or greater than 30 percent if an independent auditor certifies that the low income rate for the GE program is two
- thirds or more and the program is a degree program with a completion rate of 70 percent or more or, if the program is not a degree program, its placement rate is 44 percen t or more. Based upon FY 2011 submissions, there were 6 economically disadvantaged appeals of the total 510 challenges, requests for adjustments, and appeals. Therefore 9 (1 percent) of the projected 943 challenges, adjustments, and appeals are projected to be economically disadvantaged appeals. WeICRAS 2015 1 845
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– State, Local or Tribal Governments 2 / 3 /201 4

estimate that preparing and submitting an economically disadvantaged appeal would take an institution 5 hours for each program. We estimate that 1 (5 percent) of the 9 projected economically disadvantaged appeal s would be from public institutions. Therefore, burden would increase at public institutions by 5 hours (1 program times 5 hours) under OMB Control Number 1845
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TO TALS Responses 79 Respondents 79 Burden Hours 288