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EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **National Student Loan Data System Data Collection A. Justification**  1. Explain the circumstances that make the collection of information necessary. I dentify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or auth orizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review ty

pe of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . I f revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. Title IV, Part G of the Higher Education Act of 1965, as amended by the 1998 Amendments to the HEA (P.L. 105 - 244) section 485B, requires the S ecretary of Education to establish a National Student L oan Data Sy stem (NSL DS) that contains information about Federal Famil y Education Loan (FFEL) Program loans, Federal Perkins loans (including National Direct Student L oans and National Defense Student L oans), William D. Ford Direct Student loans (Direct Loan), Federally Insured Student Loans (FISLs) and Federal Grants (including PELL, Academic Competitiveness Grants (ACG), National Science and Mathematics Access to Retain Talent (SMART) and Teacher Educ ation Assistance for College and Higher Education (TEACH) Grants. NSLDS is used for research, policy

anal ys is, monitoring student enrollment, identifying loan holders and servicers, calculating default rates, monitoring program participants, and verifying student aid eligibility . 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. NSL DS collects data from the following sources:

 **Access and Identity Management System (AIMS) —**  AI MS authorizes users to log in 1 Please limit pasted text to no longer than 3 paragraphs.2

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) once to access multiple FSA sy stems. With AI MS, NSL DS users are able to access the NSL DS Professional Access Web site using their FSA User ID and password for identity authentication.  **Central Processing System (CPS)**

— CPS sends the NSLDS a dail y prescreen ing feed identifying applicants for new or additional Title IV aid. The NSLDS returns to CPS financial aid history

data for an y applicant found in the NSL DS database. In addition, CPS submits demographic data on a daily basis. NSL DS loads the student demographic data into the database after a student/borrower has been created as a result of a data provider reporting title IV aid. The NSLDS notifies CPS when eligibility has changed using the postscreening process.  **Common Origination and Disbursement (COD) —**  C OD sends the NSLDS a daily feed containing data on Federal Pell, ACG, and National SMART Grants.  **Total and Permanent Disability (TPD)**

— TPD sends the NSLDS a monthly file containing data on loans assigned to the Department of Education (ED) because borrower s have applied for debt forgiveness due to total and permanent disability . TPD reports permanent or conditional discharges or notifies the NSLDS that the loan has been returned to a non disability status.  **Debt Management and Collection System (DMCS)**

—DMCS sends the NSL DS a weekl y file containing data on all loans held by the Department of Education (ED) in the Debt Management and Collection Sy stem portfolio including FI SL s, Perkins loans, FDLP loans, FFELP loans, and TEACH loans. It also sends ED - held over pay ments and fraudulent grants.

 **ED Servicers** (Department contracted servicers)

— ED Servicers send weekly data files containing data on FFELP loans that have been sold to the Department as well as FDLP loans and TEACH grants. ED Servicers, also known as federal loan servicers, include the original Title IV Additional Servicers (TIVAS) and Not For Profit (NFP) organizations.

 **E -**  **mail**

— The NSLDS sends e - mails to various users for various purposes. For example, late enrollment notices are sent to schools; batch processing completion notices are sent to Federal Student Aid (FSA)/NSLDS members; new User ID notices are sent to Primary

Destination Point Administrators (PDPAs); and so on. All NSL DS originated e - mails are sent to ED’s e - mail server, whic h then distributes them over the Internet.  **Federal Student Aid Information Center (FSAIC)**

— The NSLDS sends financial aid history data for an y student/PLUS borrower found in the NSL DS database based on a “real time” request from FSAI C. This interface is to support the FSAI C Integrated Voice Response Sy stem (IVR).3

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable)

 **Financial Management Systems (FMS)**

—FMS sends the NSLDS a dail y file that contains changes to the lender participation information as well as a quarterly file that contains changes to interest rates and special allowances. The NSLDS provides summarized data about new guarantees, cancellations, and disbursements that support the Loan Processing and Is suance Fee (LPIF) pay ments by FMS, as well as data about Outstanding Principal Balance (OPB) on open l oans that support Account Maintenance Fee (AMF) pay

ments by FMS. Additionally , FMS provides Treasury summary data for the L oan Purchase Program (PUT loans).  **Financial Partners Data Mart (FPDM) —**  The NSL DS sends monthly and annual feeds of selected summary

l oan data to FPDM.  **Guaranty Agencies (GAs)**

— GAs, or their servicers, send the NSLDS at a minimum a monthly feed containing data on FFELP loans held by lenders or b y the GA itself. A Web page on the NSLDSFAP Web site allows GAs to set their submittal schedule s and view submittal details. In turn, the NSL DS sends Enrollment Reporting data to GAs on a weekl y basis and it sends backup detail data for payment of LPIFs quarterl y, and AMFs annually . The NSLDS also sends Reasonability data monthly

and annuall y to GAs . GAs also have ad hoc reporting capabilities to submit any teacher loan forgiveness (TLF) data or information about loans that are partially or totally discharged for the NSLDS to store and display .  **Lenders/Lender Servicers**

— Approved Lenders or Lender Ser vices can access NSLDS information through the Web site. L oans that are sold from the FFELP to ED as part of the L oan Purchase Program (PUT loans) are provided weekl y to NSLDS at the same time the data is being provided to FMS.  **Office of the Inspector Gen eral (OIG)**  **—** The NSL DS sends data on a monthly basis to the OIG for purposes of populating the OIG

– OI G Data Anal yt ic S ys tem (ODAS) Data Warehouse. The data sent consist of both transactional data limited to changes that have occurred in select tables and non - transactional data that provide the entire content of tables.  **Ombudsman**

— Ombudsman sends batches of student identifiers to the NSLDS, as needed. The NSLDS returns loan details.  **Participation Management (PM)**

—PM sends the NSL DS dail y files containing data on organizations and persons who have enrolled for NSLDS services. Files include organizations that will exchange batch files via SAIG with NSL DS and individuals who will access and perform functions on the NSL DS Professional Access Web site. NSLDS sends a dail y file to PM containing information of Guarant y Agencies and Lenders/Lender Servicers received from FMS and school data received from the Postsecondary

Education Participants Sy stem. The NSLDS also sends a file of users whose o nline access is to be deleted.  **Postsecondary Education Participants System (PEPS)**

—PEPS sends the NSLDS a4

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) daily file of all schools, which is used to update the school tables. The NSLDS computes draft and official cohort default rates. School, lender, and GA rates, as well as school appealed rates, are sent to PEPS. The NSLDS also provides a means to convert Campus Based School codes, FFEL School IDs, and Pell Institution codes, to Office of Postsecondary

Education I dentifiers (OPEIDs). The NSLDS provides E D users with a Web page detailing current school information.  **Schools**

— Schools, or their servicers, send the NSLDS data on Perkins loans on a monthly basis. Schools use the NSLDS Web site to report Pell, ACG, National SMART, TEACH, Perkins, and FSEOG overp ay ments. Student enrollment status is reported on a scheduled and an ad hoc basis as required b y ED either via batch submission or online update. Schools participate in the Transfer Student Monitoring (TSM) process to supply and update a list of students i dentified as transferring from one institution to another during an academic ye ar.  **Student Aid Internet Gateway (SAIG)**

— This is a private, wide area network (WAN) that serves as a store - and - forward file transfer service between the NSLDS and its many end u sers.  **Student Personal Identification Number (PIN) Site**

— Students making inquiries of the NSL DS student site are first directed to the PIN site for authentication. NSL DS users are from a variet y of government and non - government organizations, as well as individuals including:  Students;  Congressional Budget Office (CBO);  Department of Education headquarters and regional office employ ees and contractors;  Office of Management and Budget (OMB);  Guarant y agencies;  Postsecondary

schools; and  Other independent researchers. The data are collected and used for the following purposes:  **Aid Overpayment**

— The Web Aid Overpay ment function allows data providers to update the NSLDS when a student owes or repay s an overpay ment on a Pell, ACG, National SMART, TEACH Grant, FSEOG, or Perkins loan. This function also facilitates the reporting of fraud b y schools and DCS.  **Audit Support**

— Audits and risk assessments are supported by a combination of audit logs, audit reports, and Web queries.  **Cohort Default Rate (CDR) Calculatio ns**  — The NSL DS calculates draft and official default rates for schools participating in FFELP and FDLP, lenders, and GAs. NSL DS5

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) stores the numerator, denominator, and backup detail, and processes appeal rates. The cohort default rates are made available to e ach organization through the NSLDS Professional Access Web site. The school rates are made available to schools through the electronic CDR (eCDR) process. The NSLDS also calculates a draft a nd an official national default rate for each cohort ye ar. Draft CDRs will be published in the winter and the official rates will be published in the summer of each ye ar.  .
 **Credit Reform Act Support** - The Credit Reform Act and related OMB circulars req uire the Department to identify loans b y loan program, cohort year, and risk category. NSL DS is the Department’s only source of this loan - level data. NSLDS makes available the data that ED’s Budget Service requires for this purpose.

 **Customer Support**

— N SL DS personnel from the Customer Service Center (CSC), Business Operations Support, Data Integrity Group (DIG), and Qualit y Assurance (QA) document, research, negotiate, and resolve NSL DS data conflicts. Customer help involves providing full service help t o all NSLDS customers and authorized users. NSL DS customers and users include schools, guaranty agencies, lenders, FSA staff, FSA contractors, state agencies, and third part y servicers. Users require technical assistance with all the required business se rvices provided by NSLDS. Assistance topics include: website securit y; navigation of the website; updating data on the database; batch processing, which includes enrollment reporting, student transfer monitoring, data provider submittals, financial aid h istory requests, user reports/queries; and production control. NSLDS customers require a central source for resolving and negotiating data conflicts that impede awarding financial aid to students. Responding to the users requesting technical assistance as described above needs support from professionals with higher education financial aid experience. Additionally , research of these technical issues requires use of the NSL DS database and tools. International customers need to be able to contact NSLDS in th e same manner as the continental United States customers. NSL DS is also required to provide customer help services to Spanish - speaking customers. The hours of availability for customer help need to reflect customer needs across United States time zones. Additional customer help includes providing formal training for ED staff on NSL DS, its functions and uses -- in particular, how to query the database -- as well as providing informal training for NSLDS customers in PC labs and sessions at various student finan cial aid conferences. Customer help also includes preparation of user documentation and assistance with interpreting the documentation.

 **Enrollment Reporting**

— The NSLDS generates and sends Enrollment Reporting Rosters to schools. Schools or their servicer s (often the National Student Clearinghouse) can respond to the reports by

batch submission or by

entering data online. The NSLDS then updates its database to reflect an y changes in student enrollment status and forwards enrollment status change data to th e loan - holding community .6

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable)  **Federal Emergency Management Agency (FEMA)**

— The NSLDS provides an interface with FEMA for individuals affected b y disasters. Through the application process, disaster victims can appl y for assistance on FEMA’s Web site and will be given the opportunity

to review their Federal Student Aid information that is stored in NSL DS. The interface takes applicants seamlessl y to the NSL DS Student Access Web site where they must verify

their identifiers and enter their PINs.  **Online Loan Upd ate** 
—The NSLDS allows approved GAs and designated ED users to update their loan data via the Web. This instantaneous update feature helps to reduce the turnaround time for problem resolution and error corrections.  **Postscreening for Title IV Aid Eligibility**

— The NSL DS postscreens Title IV aid applicants to identify

those whose eligibility

status has changed since the time of their original aid application. The process screens for default, overpay ment, and fraud convictions, as well as loan eligibility criteri a.  **Preparation of Financial Aid History (FAH) Information**

— The NSLDS generates FAH information and forwards it to CPS as part of the prescreening process. The NSLDS also generates FAH information outside the prescreening process in response to ad hoc reque sts from schools. These requests can be made online or by batch submittal, and are part of Transfer Student Monitoring. GA can make FAH requests by batch submittal and the returned data are restricted to borrowers with whom they hold or held a loan. The FA H information they

receive contains only

borrower and loan data. No grant information is included in the FAH for GAs.  **Prescreening for Title IV Aid Eligibility**

— The NSL DS prescreens all Free Application for Federal Student Aid (FAFSA) applicants for Title IVAid to identify those applicants who are in default on an existing Title IV loan; who owe overpay ments on Pell, ACG, National SMART Grants, TEACH Grants, FSEOGs, or Perkins loans; or who have come close to or exceeded aggregate loan limits.  **Real Time D ata Inquiries** 

— The NSLDS generates FAH information in response to “real time” requests from ED applications. The following applications use this functionality :

– Direct Loan Exit Counseling using extensible markup language (XML)

– FSAI C Integrated Voice Respons e (IVR) S ys tem  **Repayment (Notional) Information**

— The NSLDS provides schools summary and detail student repay

ment data for informational purposes.  **Security Control**

—ED and Contractor User IDs, and the access these IDs have to NSL DS resources, are maintained by the Sy stems Security

Officer (SSO)/Alternate via the NSL DSFAP Web site.  **Security Monitoring**

— The NSLDS provides monitoring tools that an organization’s7

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) Primary Destination Point Administrator (PDPA) and Federal Student Aid (FSA) can use to ensure that users are compliant with NSLDS rules of access. NSLDS sy stematically monitors and provides e - mail notifications to PDPAs so they are alerted and can take the appropriate and necessary actions. NSL DS provides an ad - hoc Adobe PDF reporting capability to help monitor user activities, as well as reports delivered via SAIG mailboxes.  **Transfer Student Monitoring**

— The NSL DS receives school profile and transferring student information via Web pages and/or batch programs. It monitors each of these students for specific changes in loan and Pell, ACG, National SMART, and TEACH Grant status. The NSLDS reports these changes to schools via Web pages or batch programs. Alert e - mail is provided. NSLDS Customer Service and authorized FSA Program Compliance personnel hav e access to view a school’s Web pages to provide support and oversight.  **Web Inquiries**

— The NSLDS provides Web access for schools, state grant agencies, eligible and approved GAs, lenders and lender services, students, and ED and its contractors to view NSL DS data. Depending on user access, the Web site also provides a list of reports that can be requested to receive organization - specific data from NSLDS. To help protect a student’s/borrower’s personally identifiable information (PII) data, NSLDS masks SSNs on Web pages. The NSLDS student web site was mandated by the 1998 amendments to the Higher Education Act of 1965. In accordance wit this mandate NSL DS provides students access to their own information stored in NSLDS. In order to access their data, the s tudent must have PIN, assigned through the FSA PIN web site.  **Assessment of FFELP, FDLP, and Other Program Administration**

— The NSLDS supplies data used in short - or long - term studies aimed at determining the effectiveness of particular loan program practice s.  **Audit and Program Review Planning**

— The NSLDS supplies auditors and program reviewers with data on specific organizations and on key indicators used to schedule audits and program reviews for maximum effectiveness. ED’s contractor supports various secur ity

audits.  **Budget Analysis and Development**

— NSLDS data on loan program performance are used to support assumptions for estimating the long - term budgets for the Federal student aid programs. These data are also used to answer budget - related questions and to support “what - if” anal ys es.  **Freedom of Information Act (FOIA) requests**

— The NSLDS completes FOIA requests when they

meet established guidelines.  **Loan Participation Program (LPP) –**  NSLDS contains data regarding Custodian and Sponsor lending organization s that are part of the ECASLA enacted funding process that allows participation interest agreements with ED. NSLDS links loans on NSL DS with the Custodian or Sponsor records received from FMS.8

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable)  **Loan Transfer Tracking**

— The NSLDS preserves historical data on loan holders and loan sales dates used to understand secondary market activity , identify

potential problems with loan program participants, assist borrowers in locating lenders or GAs associated with their loans, and assessing the administration and billin g practices of Title IV loan programs.  **Monitoring GA and Lender Financial Reporting for Reasonability**

— The NSLDS supplies ED personnel with the detailed - level information needed to assess the reasonabilit y of financial reporting from GAs and lenders based on changes in loan portfolios, loan status, loan balance information, and other loan details. The NSLDS performs monthly

and annual reasonability calculations for GAs.  **Payment Support of Loan Processing and Issuance Fees (LPIFs) and Account Maintenance**  **Fees (AMFs) to GAs**

— The NSLDS provides summarized data about new guarantees, cancellations, and disbursements that support the LPI F pay ment by FMS. The NSLDS also provides data about Outstanding Principal Balance (OPB) on open loans that support AMF pay ments by FMS.  **Research Studies and Policy Development**

— The NSLDS supports long - term research studies and short - term policy development by

providing ED with current detailed and aggregated loan, grant, and student data. . NSLDS has been maintaining informatio n about loans, grants, students, borrowers, lenders, GAs, schools, and servicers since 1994 for loans that were open as of October 1989. It provides an integrated view of federal loans and grants during all stages of their life cy cle, which includes disbursement, repay ment, default, and closure. The large amount of data collected over time has resulted in NSLDS’ being used for man y anal yt ical functions including research, policy development, and program management and oversight. Users accessing data from NSL DS for research purposes include ED personnel, other federal agencies, guarant y agencies, lenders, schools, and independent researchers. Users accessing data from NSL DS for program management and oversight purposes include ED personnel only .  NSL DS pr ovides data to users through ad hoc queries, predefined reports, and extracts. Ad hoc queries range from simple queries, pertaining to a single student for relativel y small amounts of data, to complex queries requiring NSLDS to summarize large amounts 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 respons es, and the basis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. The Department of Education has selected an Information Engineering (IE) methodology using Computer Aided Sy stems Engineering (CASE) tools to design and maintain NSL DS. This9

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) enables the Department to provide and maintain verification and formatting softwa re for most data providers (i.e., those who use MVS and MS/DOS operating s ys tems). The Department provides software specifications to data providers using other operating s ys tems. In addition, the Department is accepting all data electronicall y to reduce the burden associated with data entry and forms handling. The Department has enhanced the NSLDS web functionality to allow schools, and guarant y agency to update records in real time, performing the same editing used in batch updates. This is especial ly

useful for guarant y agencies when error’s impacting a student’s eligibility need to be quickly

resolved. The web updating process includes importing and load data directl y for a data provider PC or mainframe in to NSLDS web site. The Department has also consulted extensively with the Community

regarding s ys tem design to ensure that the design places the least possible burden on data providers for example; an extract based approach for providing data to NSLDS was developed based upon input from schoo ls and guarant y agencies, as well as upon design considerations. This includes allowing all data providers to establish their own reporting schedules to NSL D S (with monthly being the minimum) as long as it is provided within NSLDS reporting guidelines. This offers the simplest requirement for data providers, while maximizing the potential for timely submission of accurate data from the community . Finall y, taking advantage of the central NSLDS database to perform Enrollment Reporting and Transfer Stud ent Monitoring streamlines these processes and enables schools that wish to automate their own processes to do so. Schools are able to update individual enrollment information through the NSLDS web site, streamlining the school’s administration of enrollme nt tracking. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. The Department reviewed its existing Title IV sy stems to identify an y instances where required data is alread y collected or maintained. In those cases, NSLDS either (a) takes the data from the existing sy stem instead of levying additional burden on the community , or (b) replaces the existing data col lection effort. One of the first significant reporting processes eliminated by NSL DS was the guaranty agencies requirement to report all FFEL loan volume on the Annual Loan Tape Dumps. Additionally NSLDS is now used to calculate the loan guarant y, disbursement, and cancelation data once reported by guarant y agencies on the quarterly Guarant y Agency Financial Report Form. This provides the Department the loan level detail to support the pay

ment of the L oan Processing and Issuance Fee agencies on the quarterl y Guarant y Agency Financial Report reducing the agency ’s reporting burden. As new regulations and laws are enacted NSLDS is used by the Department to collect additional data or provide oversight with minimal impact to schools, lenders and guaranty ag encies.10

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 5. If the collection of information impacts small businesses or other small entities, describe any 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 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 , count y, town, township, school district, or special district with a population of less than 50,000. The Department has designed NSLDS to accommodate reporting through Personal Computer, which is the minimal equipment required to participate in Title IV Aid Programs. The Department provides software to data providers with the most common ty pes of personal computers, which reduces the amount of burden on smaller organizations. The Department distributes Personal Computer software that can be use d to develop the NSLDS extract for data providers without existing databases. In addition, the Department accepts data from an y source (e.g., servicer, guarant y agency, school) designated by an organization, at the organization’s request.

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. The Department has worked with the financial aid communi ty reporting to NSL DS to increase frequency in reporting. Internal s ys tems, including Federal Loan Servicers, report to NSLDS weekl y and 50 % of the guarant y agencies report more frequently than monthly will the remaining agencies and schools report at l east monthly . Guarant y Agencies have the ability to update loan data in real time using the NSLDS on - line updating capabilities. This ensures that all of the functionality

listed in item #2 are based on the most current data. . This minimizes the amount of student aid that is awarded to students who are ineligible, as well as ensures that data corrections are received quickly for students whose aid applications have been erroneousl y rejected as a result of prescreening or post screening. Each day’s de lay in using accurate data to prescreen aid applications may represent a significant cost to the Government, especiall y with the implementation of 100% direct lending - .11

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 7. Explain any

special circumstances that would cause an information collection t o be conducted in a manner:
 requiring respondents to report information to the agency more often than quarterl y; Many of the business functionalities in which the NSL DS data is used require the timely reporting of loan balances and loan statuses. Thus, Department held loans and grants are reported weekl y, at least half of the guarant y agencies report more frequently monthly and the rest of the agencies and Perkins school report monthly .

 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it; N/A
 requiring respondents to submit more than an original and two copies of any document; N/A  requiring respondents to retain records, other than health, medical, government contract, grant - in - aid, or tax records for more than three y ears; N/A  in connection with a statistical survey , that is not designe d to produce valid and reliable results than can be generalized to the universe of study ; N/A
 requiring the use of a statistical data classification that has not been reviewed and approved b y OMB; N/A
 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 N/A
 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. N/A
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 t o that notice and12

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 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 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 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 y ears – even if the collection of 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. The Department of Education consulted with guaranty agencies, through the National Council of Higher Education L oan Resources (NCHER), and school s, through a Financial Aid Administrators Advisory

Panel and the Direct Loan Coalition. Annually NSL DS makes presentations at the Federal Student Aid Conferences, where ideas and concerns are solicited from attendees. NSLDS frequentl y sponsors webinars and participates in Federal Student Aid’s quarterl y software vendors conferences. The Department attends and conducts formal and informal meetings, presentations, question - and - answer sessions, and interviews with a variety of student aid community

represent atives and organizations. We addressed data availability , collection frequency , processing requirements, data elements to be reported, and data formats. Substantive discussions continue with members of NCHER’s Program Operations NSL DS Sub Committee , mee ting quarterl y to discuss on going enhancements and issues. NSLDS regularl y meets with focus groups and representatives from the schools. Representatives participate in regular meetings and conference calls with the Department and with the NSLDS contract or regarding data requirements and definitions and the NSLDS design. These representatives from NCHER and the schools consult with other members of the communit y and provide comments to the Department so that the widest possible insight from the financial aid community is brought into NSL DS design sessions.

9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification . There were no decisions to provide an y pay ments or gifts to respondents, other than remuneration of contractors or grantees.13

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 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 I mpact 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 Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confide ntiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. There were no assurances of confidentiality provided to respondents. The information collected here is availab le to the public under the Privacy Act of 1974. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justifi cation should include the reasons wh y 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 an y steps to be taken to obtain their co nsent. There are no questions of a sensitive nature in this collection of information. 12. Provide estimates of the hour burden of the collection of information. 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 tribal 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. Unless directed to do so, agencies should not conduct special survey s to obtain informatio n 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 widel y because of differences in activity , size, or complexity , show the ran ge 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.

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 Append ix 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)14

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable)  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 ROCI S IC Burden Analy sis Table . (The table should at minimum include Respondent types, IC activity , Responde nt 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 outs ide parties for information collection activities should not be included here. Instead, this cost should be included in Item 14. Approximately

33 guaranty

agencies and 1868 schools report to the NSLDS. The reporting burden for these organizations vari es because of differences in size and function. Guarant y agencies’ burden varies based on the number of loans each has guaranteed and upon the number of lenders from which they must obtain data. Guaranty agencies report only

on FFEL Program loans. Schoo ls’ burden varies based on the number of students who have obtained Federal Perkins loans at each school. Also, approximately 8196 schools, that do not report Perkins loans, report various other data to NSL DS such as enrollment data and transfer student m onitoring. Direct Loans, FFEL non - defaulted loans purchased by the Department and serviced by contractors, +Federal Grants, Department held Perkins L oans, and Defaulted loans held by the Department are all reported by internal Department Sy stems. General ly , larger guaranty agencies and schools are more automated, but also have a large number of records to report. Smaller agencies and schools may use a service bureau for their processing, maintain only paper files, or use lower scale processing platforms such as microcomputers. Based on information received from NCHER and the FAA Advisory Panel, an entire spectrum of processing platforms are represented in their respective communities. The Department has estimated the range of burden hours per respondent to be 2 to 8 hours per response, with an average of 6 hours per response. The Department estimated the loan - reporting burden as follows:  The number of respondents is the number of guaranty agencies (33) plus the number of schools (1868), for a total of 1 901.  The number of responses for guaranty agencies range from one week to on month, but on average two times per month or 24 times a year. The number of responses for schools respondent is the number of months in the y ear (12).  The total of annual respons es on loan data is 23,178(36 x 24) + (1868 x 12). The Department estimated the “other data” burden as follows:  The total number of respondents is the number of Non - Perkins schools (8196)  The number of responses ranges from every other month to every

six months, but only mandated twice a y ear. The Department decided to use the mandated response of twice a ye ar for estimating.  The total annual responses to “other data” are 16,392 (8196 x 2).15

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) The Department assumed that all guarant y agencies are large, but highl y automated, relative to schools. The numbers of guarant y agencies have been reduced since the implementation of 100% direct lending. Therefore, we assumed 8 hours per response fo r the guarant y agencies. We assumed that approximately 92% of the schools submitting Perkins loans (1794) will have data submitted by

large, highl y automated, servicers, so 4 burden hours were attributed to this group. We assumed that the remaining scho ols, or 74 schools, are medium - sized and we attributed slightly

more burden hours (8) to this group to allow for internal process on microcomputer - based s ystems and some mainframes. We assumed approximately 88% of the schools submitting “other data” (6328 ) will have the data submitted by large, highl y automated servicers, so 2 hours were attributed to this group. We assumed the remaining schools, or 1868schools, are medium - sized and we attributed slightly more burden hours (6) to this group to allow for internal process. We multiplied the total annual burden hours b y the average burden hours to obtain the annual burden hours of 157,456. These calculations are presented below: Respondent/Ty

pe Number of respondents Responses

per month Responses

per Year Average

number or hours per response Total

Burden Hours Guarant y Agencies 33 24 792 8 6,336 Services Schools

– Perkins 1,794 12 21,528 4 86,112 Non - Serviced Schools

– Perkins 74 12 2,088 8 16,704 Serviced Schools

– “Other Data” 6,328 2 times per year 12,656 2 25,312 Non - Serviced Schools

– “Other Data” 1,868 2 times per year 3,736 6 22,416 **TOTAL 10,097**  **40,800 156,880** 

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 and16

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 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 s ys tem 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 tes ting equipment; and acquiring and maintaining record storage facilities.
 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 colle ction 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 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 Guarant y Agencies and Schools start up cost would have been in 1994 so should not be a part of this document . Group 1 Total Annualized Capital/Startup Cost : N/A Group 1 Recurring Costs: Cost Element Amount CPU time for extract & edits .25 hours/week @ $1,000 $28,080.00 Operations staff to schedule run & prepare data to transmit 2 hours/week @ $30.00 6,739.00 Error correction 4 hours/week @ $30.00 22,464.00 **Total Group I Recurring Costs** $57,283.00 **Group 2 Recurring Costs:** Total Annualized Capital/Startup Cost : N/A

CPU time for extract & edits $0 .25 hours/week @ $1,000.00 $017

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable)

Operations staff to schedule run & prepare data to transmit 2 hours/week @ $30.00 $6,739.00 Error correction 4 hours/week @ $30.00 $22,464.00 **Total Group 2 Recurring Costs** $29,203.00 Total Respondents Cost $86,486.00 The above estimates were based on these assumptions:  Due to the diversit y of the respondents' environments, costs are divided into two groups.  Group 1 - shows the costs for the larger mainframe environments.  Group 2 - shows the costs for a smaller organization using a microcomputer as the processing platfo rm.  Costs are recurring costs.  Cost per man - hour includes salary and overhead. All Group 2 organizations have access to a microcomputer that is not billed by CPU hour. 14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantif ication 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. Cost Element Amount Contract cost, including design, Development and operations For FY 1 2 , FY 1 3 , FY 1 4 $ 34,929,136 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 m ateriall y changes a18

EDICS Tracking and OMB Number: (XXXX) XXXX - XXXX Revised: XX/XX/XXXX RIN Number: XXXX - XXXX (if applicable) 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 , respon ses and cost s (if applicable) . The total burden hours of 156,880 have decreased in volume because of the impact of 100% direct lending. Federal Loan servicers are servicing more and more of the l oans . 16. For collections of information whose results will be published, outline 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, publication dates, and other actions. This information is not intended for use as a statistical publication. 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 expiration date for OMB approval of the information collection will be display ed. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. Th e collection of information complies with % CFR 1320.9