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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify any

legal or administrative requirements that necessitate the collection. Attach a hard copy of the 

appropriate section of each statute and regulation mandating or authorizing the collection of 

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

Section 455(a)(1) of the Higher Education Act of 1965, as amended (the HEA) provides 

that unless otherwise specified, loans made under the William D. Ford Federal Direct 

Loan (Direct Loan) Program are to have the same terms, conditions, and benefits as loans 

made under the Federal Family Education Loan (FFEL) Program. The benefits available 

to borrowers under the FFEL Program include provisions for forbearance based on 

service in a medical or dental internship or residency program, national guard duty, and 

having loans repaid under the Department of Defense’s Student Loan Repayment 

Program and federal education loan debt burden (see §428(c)(3) of the HEA and 34 CFR 

682.211(h)(1) or 685.205(a)(3), 682.211(h)(2)(iii) or 685.205(a)(7), or 

682.211(h)(2)(ii)(B).

The HEA requires borrowers to agree to the terms of internship/residency or loan debt 

burden forbearances in writing. In addition, the Direct Loan and FFEL Program 

regulations require borrowers to provide sufficient documentation to establish that they

meet the statutory and regulatory criteria for a forbearance. The 

Internship/Residency/National Guard/DOD Repayment Plan Forbearance Request and 

Loan Debt Burden Forbearance Request forms serve as the means by which Direct Loan 

and FFEL borrowers fulfill these requirements. 

The U.S. Department of Education (Department) is requesting a revision of the currently

approved collection. We are simplifying and streamlining the forms such that they are 

easier for borrowers to complete.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new 

collection, indicate the actual use the agency has made of the information received from the 

current collection.

The Department and FFEL Program lenders and servicers will use the collection of 

information on the currently approved Internship/Residency, National Guard Duty, and 

 

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Please limit pasted text to no longer than 3 paragraphs.
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

Department of Defense Student Loan Repayment Program Forbearance Request and 

Loan Debt Burden Forbearance Request forms to collect the information needed to 

determine that a Direct Loan or FFEL borrower is eligible for forbearance based on 

service in a medical or dental internship or residency program, national guard duty, or 

participation in the Department of Defense Student Loan Repayment Program or based 

on federal education loan debt burden. The collection of information on the revised 

forms in this clearance package continues to be necessary and will be used for the same 

purpose. If the Department and FFEL Program lenders and servicers did not collect this 

information, a Direct Loan or FFEL borrower would not be able to request and agree to 

the forbearances.

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms of 

information technology, e.g. permitting electronic submission of responses, and the basis for the 

decision of adopting this means of collection. Also describe any consideration given to using 

technology to reduce burden.

This collection of information does not involve the use of technological processes such as 

electronic submission of requests. The Department continues to examine the extent to 

which automated or technological collection techniques are feasible.

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.

There is no information already available from other sources that can be used to establish 

a borrower’s eligibility for the forbearance. 

5. If the collection of information impacts small businesses or other small entities, describe any

methods used to minimize burden. A small entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently

owned and operated and is not dominant in its field; or (3) a small government jurisdiction, 

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

No small businesses are affected by this information collection. 

6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing 

burden.

The frequency with which a borrower must request a forbearance is determined in 

accordance with statutory and regulatory requirements that are explained on each 

forbearance request form. Less frequent data collection would not allow loan holders to 

process borrower requests for forbearance. 
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, 

grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and reliable 

results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established in 

statute or regulation, that is not supported by disclosure and data security policies that are 

consistent with the pledge, or that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to protect 

the information’s confidentiality to the extent permitted by law.

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

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to 

submission to OMB. Summarize public comments received in response to that notice and 

describe actions taken by the agency in response to these comments. Specifically address 

comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or 

reported.

Consultation with representatives of those from whom information is to be obtained or those 

who must compile records should occur at least once every 3 years – even if the collection of 

information activity is the same as in prior periods. There may be circumstances that may

preclude consultation in a specific situation. These circumstances should be explained.

The Department considered comments from the public when developing the currently 

approved forms. Furthermore, the Department will consider any comments provided 

during the 60-day comment period and will consider comments from the public during 

the 30-day comment period.
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

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

of contractors or grantees with meaningful justification.

No payments or gifts have been provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

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

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

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

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

under which those disclosures may occur.

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered private. 

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

None of the forms request information of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden was 

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. Unless directed to do 

so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

 

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

respondents is desirable. If the hour burden on respondents is expected to vary widely 

because of differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, estimates should 

not include burden hours for customary and usual business practices.

 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.

The previous filing included mathematical errors in the total number of hours:

Form Respondents/

Responses

Hours/response Previous Total Corrected 

Total

SERV 19,689 .25 4,922.25 4,922

SLDB 6,153 .20 1,230.60 1,231

TOTALS 25,842 Incorrectly 

calculated and 

reported as:

5,814.

6,153

Using these corrected numbers as a revised starting point, the information below shows 

the Department’s estimates of the total annual number of respondents, responses and 

burden hours for this information collection.

The Department estimates the total annual number of respondents for this collection to 

be 25,842. The estimated response time for the internship/residency, National Guard 

duty, and DOD repayment plan forbearance is .25 hours (15 minutes) with one response 

per estimated 19,689 respondents. The estimated response time for the student loan debt 

burden forbearance is .20 hours (12 minutes) with one response per estimated 6,153 

respondents. This equates to a total estimated reporting burden of 6,153 hours. The 

burden estimate for each form was calculated as follows:

Internship/Residency Forbearance, 

National Guard Duty, DOD Repayment 

Plan

Estimated annual number of respondents: 19,689
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

Number of responses per borrower: x 1

Hours per response: x 0.25

4,922 hours

Loan Debt Burden Forbearance

Estimated annual number of respondents: 6,153

Number of responses per borrower: x 1

Hours per response: x 0.20

1,231 hours

There is a minor increase to the total burden hours of 339 hours due to a mathematical 

error in the previous filing.

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

systems or purchasing services.

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden shown 

in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into account 

costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and 
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

usual business or private practices. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : $0.00

Total Annual Costs (O&M) : $0.00

____________________

Total Annualized Costs Requested : $0.00

There are no capital/startup costs to respondents.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description 

of the method used to estimate cost, which should include quantification of hours, operational 

expenses (such as equipment, overhead, printing, and support staff), and any other expense that 

would not have been incurred without this collection of information. Agencies also may

aggregate cost estimates from Items 12, 13, and 14 in a single table.

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

Program, Direct Loan, or Perkins Loan borrowers, since loan holders and servicers

distribute and process the loan discharge applications, and the Department’s servicers do 

not specifically charge the government for distributing these forms.

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 

should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

This is a request for a revision of the current information collection 1845-0018. There is 

a minor increase to the burden hours of 339 hours due to a mathematical error in the 

previous filing total. There are no changes to the information collected on these forms 

however, the forms have been simplified and reformatted to present a common layout for 

these types of requests. There has been no change in the underlying statute or regulations 

which support these request forms.

16. For collections of information whose results will be published, outline plans for tabulation 

and publication. Address any complex analytical techniques that will be used. Provide the time 

schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

The results of this information collection will not be published.
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OMB Number: 1845-0018 Revised: 3/9/2015

RIN Number: N/A

17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

The Department is not seeking this approval.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The Department is not requesting any exceptions to the "Certification for Paperwork 

Reduction Act Submissions".