OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0)

i 

### SUPPORTING STATEMENT **FOR PAPERWORK REDUCTION ACT SUBMISSION**

**OMB Number: 1845 -**  **0077 Table	of	Contents**  A. Justification ................................ ................................ ................................ ................................ ................................ 1 1. Explain the circumstances that make the collection of information necessary. ................................ ........................ 1 2. Indicate how, by whom, and for what purpose the information is to be used. ................................ ........................ 2 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; ................................ ................................ ................................ ................................ ...................... 3 4. Describe efforts to identify duplication. ................................ ................................ ................................ .................... 3 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. ................................ ................................ ................................ ................................ 4 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently. ................................ ................................ ................................ ............................... 4 7. Explain any special circumstances that would cause an information collection to be conducted in a manner: ................................ ................................ ................................ ................................ ........................... 5 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. ................................ ................................ ................................ ................................ ......... 5OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0)

iii 9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification. ................................ ................................ ................... 6 10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. ................................ ................................ ................................ .............. 6 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. ................................ . 6 12. Provide estimates of the hour burden of the collecti on of information. ................................ ................................ .. 7 13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. ................................ ................................ ................................ .......................... 8 14. Provide estimates of annualized cost to the Federal government. ................................ ................................ .......... 9 15. Explain the reasons for any program changes or adjustments. ................................ ................................ ............. 10 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques t hat will be used. ................................ ................. 11 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. ................................ ................................ ............ 11 18. Explain each exception to the certification statement identified i n the Certification of Paperwork Reduction Act. ................................ ................................ ................................ ................................ ............... 111

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) 

### 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 pro**  **vide a valid URL**  **link or paste the applicable section 1**  **. 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 Higher Education Act of 1965, as amended, (HEA) allows for up to a one hundred percent cancellation of a Federal Perkins Loan and loan forgiveness of a Federal Family Education Loan and Dire ct Loan program loan if the graduate teaches full - time in an elementary or secondary school serving low - income students. The data collected for the development of the Teacher Cancellation Low Income Directory provides web based access to a list of all e lementary and secondary schools, and educational service agencies that serve a total enrollment of more than 30 percent low income students (as defined under Title I, Part A of the Elementary and Secondary Education Act of 1965, as amended). The Director y allows postsecondary institutions to determine whether or not a teacher, who received a Federal Perkins Loan, Direct Loan, or Federal Family Education Loan at their school, is eligible to receive loan cancellation or forgiveness or that a teacher who r eceived a TEACH Grant is meeting the service obligation. The regulatory authority governing the Teacher Cancellation process for the loan programs and the verification of the obligation to serve for the TEACH Grant for which the TCLI Directory is used a re: Federal Perkins Loan funds 34 CFR 674.53 ; Federal Family Education Loan (FFEL) 34 CFR 682.216 ; Wi lliam D. Ford Direct Loan (DL) Program 34 CFR 685.217 ; and Teacher Education Assistance for College and Higher Education (TEACH) Grant Program 34 CFR 686.40 .

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

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) Effective August 14, 2008, The Higher Education Opportunity Act (P. Law 110 - 315) amended section 465(a)(2)(A) of the Higher Education Act of 1965, as amended, to authorize loan cancellation or forgiveness for full

- time teaching service in locations operated by an educational service agency. Sections of the Higher Education Act of 1965, as amended, that govern these programs can be found at the Offic e of Postsecondary Education Policy Resource page . The list of schools and educational service agencies that serve low - income families in the TCLI Directory qualifies teachers for loan cancellation under the Federal Perkins Loan Program, and loan forgiveness under the Federal Family Education Loan (FFEL) Program and the William D. Ford Federal Direct Loan (Direct Loan) Program. This list also satisfies certain aspects of the teaching ob ligation in the Teacher Education Assistance for College and Higher Education (TEACH) Grant program. If a State does not update its list of low

- income schools, Perkins, FFEL and Direct Loan borrowers and TEACH Grant recipients who teach in that State may not receive Federal program benefits to which they may be entitled. Changes being made to the TCLI Directory No additions are being made to the data collection. This submittal is to:
 Renew the expiration date as it expires 6/30/2015,  Provide updated addr ess information, and  Provide minor verbiage update. 

### 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.** Information is obtained from State Agencies that contribute to the development of a directory of elementary and secondary schools and educational service agencies that serve low- income families that qualify for the teacher cancellation benefit . Failure to collect this information would prevent teachers from receiving specific student loan cancellations or knowing if they are meeting requirements of the TEACH Grant. Colleges and universities use the information in the Directory to research scho ols that meet the criteria for their students to take advantage of specific student loan teacher cancellation and TEACH Grant benefits. The public (students and their families) use information in the Directory to research career choices that will allow the m to take advantage of specific student loan teacher cancellation and TEACH Grant benefits.3

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) 

### 3.		Describe	whether,	and	to	what	extent,	the	collection	of	information	involves	the	use	of **automated,	electronic,	mechanical,	or	other	technological	collection	te chniques	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 Teacher Cancellation Low Income Directory is a web - based system. Changes and updates to the directory may be made whenever necessary. Also, any changes to the directory are made in real time. This allows students who may be authorized to have all or part of the ir loans forgiven for teaching at schools that meet the criteria as being designated as a low income school to have access to immediate and accurate data. The Teacher Cancellation Low Income directory can be accessed at https://www.tcli.ed.gov. 

### 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.**  The TCLI Directory data collection requires inclusion of both public and private nonprofit elementary and secondary schools and educational service agencies where more than 30 percent of the school's or educational service agency's total enrollment is made up of children who qualify for services provided under title I. Standard language provided to the state contacts providing the data explains the flexibility of the state in determining the measure of 30%: To qualify for inclusion on the Directory of Designated Low Income Schools, a school must be in a school district of a local education agency that is eligible for assistance under Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA), and the school must be a school "in which the number of children meeting a measure of poverty under section 1113(a)(5) of the Elementary and Secondary Education Act of 1965, exceeds 30 percent of the total number of children enrolled in such school" (Section 465(a)(2)(A)(i)(I), Higher Education Act of 1965, as amended). The "measures o f poverty," as set out in section 1113(a)(5) of the ESEA , are : "(5) MEASURES - The local educational agency shall use the same measure of poverty, which measure shall be the number of children ages 5 through 17 in poverty counted in the most recent census data approved by the Secretary, the number of children eligible for free and reduced priced lunches under the Richard B. Russell National School Lunch Act, the number of children in families receiving assistance under the State program funded under part A of title IV of the Social Security Act, or the number of children eligible to receive medical assistance under the Medicaid program, or a composite of such indicators, with respect to all school attendance areas in the local educational agency. . ."4

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) The av ailability of the most current data is of concern for the teachers meeting the specific requirements for loan forgiveness and or meeting the service requirements of the TEACH Grant. Each year, in July, the TCLI Directory is updated to accept the most rece nt year data while also continuing to accept updates and changes to data in past years. The current data provided by the states is available real- time and the system is open year

- round for public and government use and available for update year - round by s tate contacts. FSA recognizes that EDFacts (www.ed.gov/open/plan/edfacts) does collect data from Title I schools. However, in discussions with the staff that works with the EDFacts data collection, we’ve learned that the data within EDFacts would not specifically meet the TCLI Directory immediate needs of:

• Both public and private school data : EDFacts contains public school data. Private school data would come from a different request of data.

• Flexibility in statutory options that states u se to determine the 30% measure of poverty: In order to use EDFacts data, FSA would have to define the 30% measure. Annual communications are sent to each state contact providing information and instructions concerning the current data upload to the TCLI Directory. In addition, a link to the State Contact User’ s Guide is being implemented on the TCLI Web site. 

### 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 operate d 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.**  The collection of this information does not involve 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	frequently** . **Also describe any technical or legal obstacles to reducing burden.**  If the collection is not conducted or is done less frequently, the ability to cancel student loans that qualify for cancellation throughout the school year would be hindered as explained in item 4. “Efforts to Identify Duplication” above.5

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) 

### 7.	Explain	any	spe **cial	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 informati on 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 m**  **ore 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 an d 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.**  There are no special circumstances inconsistent with these guidelines. 

### 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.**6

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) The data is requested from State agencies only. A s ixty - day Federal Register Notice w as published to allow public comment. No public comment was received. This request is for the 30 - day notice to allow for public comment. 

### 9. **Explain	any	decision	to	provide	any	payment	or	gift	to	respondents,	other	than remuneration	of	contrac** **tors	or	grantees with	meaningful	justification**  **.** There are no payments or gifts to 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 F**  **orm . A confidentiality statement with a legal citation that authorizes**  **the pledge**  **of confidentiality**  **should be provided. 2**  **If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If th**  **ere is no expectation of confidentiality, simply state that the Department make** **s no pledge about the confidentially of the data.**  The Department makes no pledge about the confidentiality of the data. 

### 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.** This collection does not include information of a sensitive nature.

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

– 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)7

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) 

### 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 narra**  **tive 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 t** 

**he 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 c ustomary 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.** There are a total of 57 State and Territorial agency respondents. The data can be updated at any time and is used by four financial aid programs in the Department. State agencies collect data from elementary and secondary schools in their districts, review the data, and update and add any new data to the Directory as necessary. In an effor t to reduce the burden to the states, Federal Student Aid maintains the TCLI Directory so that it is available year - round and is easy to use. Clarifications to online text have been added to assist in the user’ s understanding of data to be reported and ho w to upload, add, and modify data and contact information. A link to the State Contact User’s Guide has been added to the Web site so that it, too, is always available to the user. A random sample of a few State agencies showed that it took an average of three 40 - hour work weeks to collect, review and input data in the Directory. (See matrix below.)

**Est. No. of Respondents Est. Avg. Person Hours**  **per Respondent –**  **Reporting Est. Avg. Person Hours per** 

**Respondent –**  **Record Keeping**  **Total Hours**8

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0)
**State & Territorial Agencies**  57 40 80 6840 (57 x 120) **Average Salary of Respondents**  **Total Salary Cost**  **of all Respondents**  $26.90 per hour $ 183,996 ( Total hours x S alary) 

### 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 expec**  **ted 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 met hods 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 i tems, 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 sa**  **mple 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, estim ates 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 provid**  **e 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 Annualize** **d Capital/Startup Cost :**  **$0 Total Annual Costs (O&M)**  **: $0** 9

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0)

**____________________ Total Annualized Costs Requested**  **: $0**  The nature of business for State and Territorial agencies i s such that purchases of equipment and provision of services that are required for completion of their directory submissions are a part of their customary and usual business practice. They use the type of equipment and services normally necessary to succe ssfully operate any State entity. Therefore, no special equipment or services are required for providing data. 

### 14.	Provide	estimates	of	annualized	cost	to	the	Federal	government. **Also, provide a description of the method used to estimate cost, which sho uld 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 estimate** **s from Items 12, 13, and 14 in a single table.**  The matrix below descr ibes the separate costs for TCLI Directory . **TCLI Directory Publication and Distribution Costs**  The TCLI web operations and maintenance cost is incorporated into the eCampus - Based System web operations. There are no separate operations and maintenance or publication and distribution costs. **Total** $0 **TCLI Directory Operations & Maintenance Contract Costs**  

### Collabralink 8405 Greensboro Drive Suite 1200 Falls Church, VA 22 102 The current annual O&M costs for the eCB system include the FISAP and Reallocation forms 1 

### as well as the TCLI Directory

2 

### , Work Colleges Application and Expenditure forms 3 

### , and the CTP- Intellectual disabilities form 4


### . 1 

### The FISAP and Reallocation Form is a separate data collection with OMB control number 1845 - 0030 2 

### The TCLI Directory is a separate data collection with OMB control number 1845 - 0077. 3 

### The number of schools participating in the Work Colleges program is static at 7 participants. There is no OMB control number for this data collection. 4 

### The CTP form is a separate data collection with OMB control number 1845 - 0113 .10

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0)
**Note:** Annua l O&M Contract cost - $1,4 73,339 = monthly cost $1 22,778 allotted as: FISAP (8 months) = $982,226 Reallocation (1 month) = $ 1 22,778 TCLI Directory (1 month) = $ 122,778 Work Colleges (1 mo nth) = $ 122,778 CTP- Intellectual Disabilities (1 month) = $ 122,778 **Total TCLI Directory**  **O&M Costs (1 month)**  $ 1 22,778 .26 **TCLI Directory Staffing Operations and Overhead Costs**  A staff of 8 .5 FTE’s is required for the operation of the campus - based programs and the eCB system. This includes the FISAP and Reallocation forms as well as the TCLI Directory, Work Colleges Application and Expenditure forms, and the CTP- In tellectual disabilities form as footnoted above. The types of program staff include managers, accountants, financial management specialists, technicians, systems analysts, and clerical staff. The total amount of annual salaries devoted to eCampus - Based activities is $1,354,102 . Using the Salary Table 201 4 - DCB Effective January 20 14 , the average hourly wage of the cur rent staff composition is $51.02 . **Note:** The total amount of annual salaries devoted eCB activities is divided as: Reallocation (3 staff @ 120 hrs ea x $4 6.94) = $1 8,366.92 TCLI Dire ctory (1 staff @ 80 hrs x $46.94) = $4,081.54 Work Colleges (1 staff @ 160 hrs x $46.94) = $ 8,163.08 CTP- Intellectual Disabilities (1 staff @160 hrs x $46.94) = $ 8,163.08 FISAP (Total salaries less Reallocation, TCLI Directory, Work Colle ges, CTP- Intellectu al Disabilities) = $1, 402,249.38 **TCLI Directory Yearly Staff Costs**  $4,081.54 **TCLI Directory Yearly Overhead Costs**  A standard budget estimate of 16% was used to determine the overhead costs of staff operations including such items as equipment, utilities, work materials, etc. ( $4,081.54 x 16% = $653.05 ) **Yearly Overhead Costs** $ 653.05 **Total Staff and Overhead Costs to the Federal Government**  $4,734.59 

### 15.	Explain	the	reasons	for	any	program	changes	or	adjustments.11

OMB Number: 1845
- 0077 Revised: 2/ 19 /201 5 2015 Teacher Cancellation Low Income (TCLI) Directory (eCB 16.0) **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 deliberat e 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 cost**

**s (if applicable)**  **.** This is a request for an extension of the currently approved information collection 1845 - 0077. There has been no change to the underlying regulatory requirements. We are requesting a correction to the nu mber of current responses. There are only 57 responses anticipated, one for each of the affected entities. The current clearance indicates 114 responses. We believe this was a typographical error in the previous submission. While entities can submit da ta more than one time per year, the average is once a year. The estimated total annual reporting and record keeping hour burden has not changed from the current OMB inventory of 120 hours per respondent , times 57 respondents for a total burden of 6840 hou rs . 

### 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 an**  **d ending dates of the collection of information, completion of report, publication dates, and other actions.**  This information collected in the TCLI Directory is not collected for statistical publication. 

### 1 **7.	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** . There are no exceptions to the certification statement.