1

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 RIN Number: XXXX

- XXXX (if applicable)
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Health Education Assistance Loan (HEAL) Program: Lender’s Application for Insurance Claim Form (HEAL 510) and**  **Request for Collection Assistance Form (HEAL 513)**  **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 cop y of the approp riate 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 section 1 . Specify the review t ype of the collection (new, revision, extension, reinstatement wi th change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This is a request for an extension without burden change of O ffice of M anagement and B udget (OMB) approval of the Lender’s Application for Insurance Claim Form (HEAL 510) and Request for Collection Assistance Form (HEAL 513). The forms are authorized by the HEAL program. Section 525 of the Consolidated Appropriations Act of 2014 transferred the collection of the HEAL Program loans from the U.S. Department of Health and Human Services (HHS) to the U.S. Department of Education (ED). To fulfill this mandate, ED received a tr ansfer the information collection of the forms HEAL510 and HEAL 513 previously identified as OMB Control Number 0915

- 0036 to OMB Control Number 1845

- 0127. There are no changes to the forms that were approved by OMB June 25, 2014. The information colle cted on both forms is necessary to protect the financial interests of the Federal Government and to assure proper program administration by the current lenders/holders. 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. Lender’s Application for Insurance Claim Form (HEAL 510) This form represents the official request b y the institution for payment of a claim by the government and the institution’s certification that all requirements for that pay ment have been met. When a lending institution files a claim for pay ment of an insured loan, the lending institution is required to report the reason for th e claim, certain information about the claim and the amount of the claim.

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

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 RIN Number: XXXX

- XXXX (if applicable) This form is used to obtain information about the claim and to determine if the lending institution has complied with the statutory and regulatory

requirements for pay

ment of the in surance claim. Failure to submit the required documentation or not filing the form promptly may result in a claim being penalized or denied. Request for Collection Assistance Form (HEAL 513) In the event that a borrower becomes delinquent on loan pay ments, the lender must follow a specified sequence of mail and telephone and in

- person contacts with the borrower, and must record each attempt to contact each actual borrower or endorser. If the lender is unable to locate either the borrower or the endorser , skip

- tracing activities must be initiated and documented. When a borrower is 90 day s delinquent, the lender must immediately

request pre - claims assistance from ED. Pre

- claims assistance consists of three progressivel y stronger letters urging the borrow er to contact their lender before litigation is initiated against the borrower. The default claim will not be paid to the lender if they

fail to request pre

- claims assistance. Form 513 is filed to request this pre

claims assistance. This form provides the name and address of the borrower, the last school attended, and the nearest relative or guardian, the current status of the loan, including the original principal, the unpaid principal and interest, interest rate, number of pay ments made to date, the amount due per month, and the number of pay ments delinquent. The form is completed b y the lender and submitted to ED after all the lenders have implemented the required due diligence. The lenders also send documentation describing all attempts to contact , all contacts, and all skip

- tracing attempts. 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 an y consideration given to using technology

to reduce burden. The electronic transfer of information for the outstandi ng HEAL loans is currentl y done by at least 92 percent of respondents for the form HEAL 513. Form HEAL 510 is available electronically

but requires an original signature page from the lender’s authorizing official to certify that the information is correc t and follows regulation and guidelines. 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 current process avo ids duplication. There is no other sy stem available that contains the required information. 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 deemed3

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 RIN Number: XXXX

- XXXX (if applicable) 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. No small businesses are affected b y this information collection. 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. Submission of the pre

- claims assistance form is requi red b y regulation when the borrower is 90

- day s delinquent in making a pay ment. A default claim will not be paid if the lender fails to request pre

- claims assistance within the specified time. Similarly , the insurance claim will not be honored if it is no t submitted in a timely fashion, as required b y regulation. 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 quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;
 requiring respondents to submit more than an original and two copies of any document;
 requiring respondents to retain records, oth er than health, medical, government contract, grant - in

- aid, or tax records for more than three y ears;  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 ;  requ iring the use of a statistical data classification that has not been reviewed and approved b y 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 unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or
 requiring respondents to submit proprietary trade secrets, or other confidential information unl ess the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law. The collection of this information will continue to be conducted in a manner that is consistent with the guidelin es in 5 CFR 1320.5(d)(2). 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comment s received in response to that notice and4

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 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 circumstances that may preclude consult ation in a specific situation. These circumstances should be explained. There has been no change to the underl yi ng statutory or regulatory

language. There w as a 60
- day notice in the Federal Register seeking public comment on these burden calculations. No comments were received. This is the and 30

- day notice for public comment. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. No pay ments or gifts wi ll be provided to the respondents. 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 A ct 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 on 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 confidentiality . I f there is no expectation of confidentiality , simply state that th e Department make s no pledge about the confidentiall y of the data. Disclosure of the applicant’s social securit y number (SSN) is mandatory for participation in the HEAL Program, as provided for b y the Debt Collection Act of 1982, and the borrower is advis ed of this requirement at the time they apply for the loan. Safeguards are followed concerning the use of the SSN in the Privacy Act of 1974. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitu des, religious beliefs, and other matters that are commonly considered private.

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 Informatio n, OM : 6
- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)5

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 RIN Number: XXXX

- XXXX (if applicable) The justification 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 consent. ED is not requesting an y sensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public 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 c onduct special survey s 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 widel y because of differences in activity , size, or complexity , show the range 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.
 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 , 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 took over the collection of HEAL program loans beginning July 1, 20 14. Because there has not been sufficient time to have history to update the burden figures this information collection is being filed using the burden that was assessed at the last collection filing done b y HHS. When sufficient processing has been perfo rmed by ED this collection will be updated. HEAL Form 510 # of Respondents # of Responses Hours/Response Total Hour Burden 13 * 364 0.50 182 HEAL Form 513 # of Respondents # of Responses Hours/Response Total Hour Burden 13* 5,785 0.17 983 TOTAL S 6,149 0.67 1,165 *The number of lenders is not totaled as it is the same universe of participants.6

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 RIN Number: XXXX

- XXXX (if applicable) 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 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 a s purchasing computers and software; monitoring, sampling, drilling and testing 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 th e 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 anal ys is associated with the rulemaking containing the information collection, as appropriate.
 Generally , estimates should not include purchases of equipment or se rvices, 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 Total Annual Costs (O&M) : 1 , 820 Total Annualized Costs Requested : 1 , 820 There are no capital and startup costs as this activity is not a new one. The following is a breakdown of the O&M costs identified above. HEAL 510: For the estimated 364 responses a ye ar it will cost the holder/servicer approximately

$5.00 per claim for photocop yi ng the claim folder to retain for their records as the original m aterial must be submitted to ED . 364 x $5.00 per claim for a total = $1,820. Total cost for HEAL 510 and HEAL 51 3 = $2,594.00 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 that7

OMB Number: 1845
- 0127 Revised: 9 / 30 / 2014 RIN Number: XXXX

- XXXX (if applicable) would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. There are no costs to the Federal government. 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 materiall y 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 re spondent 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 chang e, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)
. As stated earlier, ED took over the collection of HEAL program loans beginning July 1, 2014, so we are not asking for either a program ch ange or adjustment at this time. We are requesting an **extension of the current collection without change in**  **burden determination**  until ED has had time to process a sufficient number of these requests and has data to accurately

report any

burden changes. 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 endin g 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 inf ormation collection, explain the reasons that display would be inappropriate. ED is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. ED is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83

- 1.