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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

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 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.

This is a request for an extension without burden change of Office of Management and 

Budget (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 

transfer the information collection of the forms HEAL 510 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 collected 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 by the institution for payment of a claim by the 

government and the institution’s certification that all requirements for that payment have 

been met. When a lending institution files a claim for payment of an insured loan, the 

lending institution is required to report the reason for the claim, certain information about 

the claim and the amount of the claim.

 

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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

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 payment of 

the insurance 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 payments, 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 days delinquent, the lender 

must immediately request pre-claims assistance from ED. Pre-claims assistance consists 

of three progressively stronger letters urging the borrower 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 preclaims 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 payments made to 

date, the amount due per month, and the number of payments delinquent. The form is 

completed by 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 any consideration given to using 

technology to reduce burden.

The electronic transfer of information for the outstanding HEAL loans is currently 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 correct and follows regulation and 

guidelines.

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 current process avoids duplication. There is no other system 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 entity may be (1) a small business which is deemed 
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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

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, 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.

Submission of the pre-claims assistance form is required by regulation when the borrower 

is 90-days delinquent in making a payment. 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 not submitted in a timely fashion, as required by 

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 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.

The collection of this information will continue to be conducted in a manner that is consistent 

with the guidelines 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 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 
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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

RIN Number: XXXX-XXXX (if applicable)

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.

There has been no change to the underlying statutory or regulatory language. There will 

be a 60-day and 30-day notice in the Federal Register seeking public comment on these 

burden calculations. 

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 will be provided to the 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.

Disclosure of the applicant’s social security number (SSN) is mandatory for participation 

in the HEAL Program, as provided for by the Debt Collection Act of 1982, and the 

borrower is advised 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 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, 

 

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

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

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

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

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

of Personally Identifiable Information)
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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

RIN Number: XXXX-XXXX (if applicable)

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.

ED is not requesting any 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 type (federal government, 

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

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

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

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

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

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

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

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

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

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

not include burden hours for customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

ED took over the collection of HEAL program loans beginning July 1, 2014. 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 by HHS. When sufficient processing has been performed 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

TOTALS 6,149 0.67 1,165

*The number of lenders is not totaled as it is the same universe of participants.
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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

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 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 

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 year it will cost the holder/servicer 

approximately $5.00 per claim for photocopying the claim folder to retain for their 

records as the original material must be submitted to ED. 364 x $5.00 per claim for a 

total = $1,820.

Total cost for HEAL 510 and HEAL 513 = $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 that 
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ICRAS Tracking and OMB Number: (2040) 1845-0127 Revised: 7/30/2014

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 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).

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 change 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 analytical techniques that will be used. Provide the time 

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

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

The results of this information collection will not be published.

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

collection, explain the reasons that display would be inappropriate.

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 any exceptions to the “Certification for Paperwork Reduction Act 

Submissions” of OMB Form 83-1.