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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

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 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 College Cost Reduction and Access Act of 2007 (Pub. L. No. 110-84) and the Higher 

Education Opportunity Act of 2008 (Pub. L. No. 110-315) amended Section 455 of the 

Higher Education Act of 1965, as amended, (the HEA) (20 USC 1087(e)(m)) to provide 

for the forgiveness of the outstanding balance of a borrower’s William D. Ford Federal 

Direct Loan (Direct Loan) Program loan(s) after the borrower has made 120 on-time, 

monthly payments under a qualifying repayment plan after October 1, 2007 while 

working for a qualifying public service organization. 

Final regulations for the Public Service Loan Forgiveness (PSLF) Program were 

published in the Federal Register on October 23, 2008 (73 FR 63256) and were codified 

in 34 CFR 685.219. These regulations require a borrower to submit an application for 

loan forgiveness to the U.S. Department of Education (the Department). To determine 

whether a borrower is eligible for loan forgiveness, the Department must confirm that the 

borrower was employed full-time by a qualifying public service organization at the time 

each of the required 120 payments was made.

Because borrowers must make 120 payments on or after October 1, 2007 before 

becoming eligible for forgiveness, the earliest that any borrower could apply for 

forgiveness under PSLF would be October 1, 2017. Consequently, no loan forgiveness 

application form is required at this time. However, as the 2017 date approaches, the 

Department will submit a Public Service Loan Forgiveness Application for clearance, to 

be included as part of the same paperwork clearance package as the Employment 

Certification. 

The Department is not making substantive changes to the forms except as follows:

 Restructuring section 3 of the form to provide discrete, yes/no questions and 

answers.

 

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Please limit pasted text to no longer than 3 paragraphs.
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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

 Adding skip logic to section 3 of the form, to making it simpler for borrowers to 

complete.

 Modifying language on the form to emphasize key points concerning the PSLF 

Program.

 Merging the separate instructions document into the form, itself.

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 Department and its Direct Loan Program servicers will use the information collected 

on the Employment Certification for Public Service Loan Forgiveness form to determine 

whether a borrower has worked for a qualified employer during the certification period 

and whether payments made against a borrower’s outstanding Direct Loan balance were 

qualifying payments for the purpose of the Public Service Loan Forgiveness (PSLF) 

program.

The submission of the Employer Certification Form prior to applying for loan forgiveness 

is done at the borrower’s discretion. While the Department recommends that a borrower 

submit the Employer Certification Form annually, the borrower could submit the form 

when changing jobs, or could wait until he or she is eligible to submit an application for 

loan forgiveness and provide all Employment Certifications at that time.

If the borrower submits Employment Certifications prior to the submission of an 

application for forgiveness, the borrower’s Direct Loan servicer will retain the form on 

the borrower’s behalf and notify the borrower many payments made during the 

certification period of employment count toward the required 120 payments.

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.

Because the Employment Certification form requires a signed certification from an 

authorized official of the borrower’s employer, electronic submission of the Employment 

Certification is not feasible.

Although this form cannot be submitted electronically, it can be downloaded and 

completed electronically using common or free software.

While the form cannot be submitted electronically, ED will continue its effort to 

maximize the use of available information technology in making and servicing Direct 

Loans when it is feasible and cost-effective.

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.
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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

There is no similar information already available from other sources that can be used for 

the purposes described in Item 2.

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, 

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 affected by this information 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.

If this collection of information were not conducted, the Department would be unable to 

determine whether borrowers are eligible for Public Service Loan Forgiveness. 

As explained in Item 2 of this Supporting Statement, the frequency of submission is 

determined by the borrower, and may be as frequent as each time a borrower changes 

public service employers. 

If borrowers were not allowed to submit employment certifications until after they have 

made all 120 required payments and are eligible to apply for loan forgiveness, there 

would be a greater likelihood that borrowers would be unable to obtain the required 

documentation of employment that ended years in the past, and it would be more difficult 

for them to track their progress toward making their 120th qualifying payment.

Further, by soliciting Employment Certification forms less frequently, the Direct Loan 

servicers would receive a large number of forms at the same time, when the first 

borrowers become eligible to apply for loan forgiveness in October 2017. This would 

lead to an increase in the time required to process borrowers’ loan forgiveness 

applications.

In summary, if the Department did not allow for Employment Certification forms to be 

submitted annually or more frequently, this would increase burden on both borrowers and 

the Department. 

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;
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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

 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.

This information collection does not involve any of the above conditions.

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, 

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.

ED considered comments from the public when developing the currently approved forms. 

Furthermore, ED consulted with borrower stakeholders prior to entering the form into 

clearance, and the public will have both a 60- and 30-day comment period during which 

they may submit comments to the proposed form. 

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

of contractors or grantees with meaningful justification.

No payments or gifts have been provided to respondents.
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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

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.

The forms include a Privacy Act Notice that (1) informs borrowers of the statutory

authority for the information collection; (2) explains that the disclosure of the information 

is voluntary, but is required in order to qualify for a loan discharge; and (3) identifies the 

third parties to whom the information may be disclosed and explains the circumstances 

under which those disclosures may occur.

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. 

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 form does not require borrowers to provide any information of a sensitive nature.

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.

 

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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: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

 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.

ED estimates the total annual number of respondents for this information collection to be

as follows:

The estimated time required to complete the forms is 0.5 hours (30 minutes). 

Based on one response per respondent, this equates to a total estimated annual reporting 

burden of 61,448 hours, calculated as follows: 

Estimated annual number of respondents: 122,896

Number of responses per borrower: x 1

Hours per response: x 0.5

(30 minutes)

Annual hour burden: 61,448 hours

This revision represents a reduction of 975,375 burden hours. This reduction is the result 

of a re-estimation of the number of borrowers who will submit the form in any given 

year. The prior estimate greatly overestimated the number of borrowers who would 

submit the form.

There are no annual costs to respondents associated with operating or maintaining 

systems or purchasing services.

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.
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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

 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 : $0.00

Total Annual Costs (O&M) : $0.00

____________________

Total Annualized Costs Requested : $0.00

There are no capital/startup costs to respondents.

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 is no significant cost to the federal government related to these forms from Direct 

Loan borrowers, since servicers distribute and process the loan discharge applications, 

and ED servicers do not specifically charge the government for distributing these forms.

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).
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ICRAS Tracking and OMB Number: (1474.07) 1845-0110 Revised: 7/21/2014

RIN Number: N/A

This revision represents a reduction of 975,375 burden hours. This reduction is the result 

of a re-estimation of the number of borrowers who will submit the form in any given 

year. The prior estimate greatly overestimated the number of borrowers who would 

submit the form.

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 this information collection 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".