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OMB Number: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Student Assistance General Provisions – Subpart A - General

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.

The recent Negotiated Rulemaking regarding Gainful Employment removed and 

reserved subparagraph (a) – “Reporting requirements.” and added §668.6(d) which 

provides a sunset provision for §668.6 as of December 31, 2016 from §668.6 Reporting 

and disclosure requirements for programs that prepare students for gainful employment in 

a recognized occupation. A new subpart Q - “Gainful Employment (GE) Programs” was 

added to 34 CFR 668 to incorporate the new regulations. The majority of the regulations 

take effect July 1, 2015. See Federal Register, Vol. 79, No. 211, pages 64890-65103 for 

the full regulatory change. However, the new requirements in §668.412 – “Disclosure 

requirements for GE programs.” have an implementation date of January 1, 2017. See 

Federal Register, Vol. 79, No 233, pages 71957-71959 for corrections.

Because §668.6 remains in effect until December 31, 2016, this request is for an

extension of approval of the current disclosure template requirements that are contained 

in the Student Assistance General Provisions regulations – Subpart A - §668.6(b) -

Disclosures. Educational programs offered by an institution of higher education 

consistent with §668.8(c)(3) are programs that are at least a one-academic year training 

program that leads to a certificate, or other non-degree recognized credential and that 

prepares a student for gainful employment in a recognized occupation. Similarly, 

programs offered by a proprietary institution of higher education or by a postsecondary

vocational institution of higher education under §668.8(d) must provide undergraduate 

training that prepares a student for gainful employment in a recognized occupation. 

The template allows institutions to input much of the required disclosure 

information which will then be combined with data maintained by the Department. Once 

these two sources of data are combined the information that will comprise the required 

disclosure will be transmitted to the institution about its gainful employment program. 

The institution will maintain this required disclosure information on its systems and 

display it, using the common output document format provided by the Department, on the 

 

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Please limit pasted text to no longer than 3 paragraphs.
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OMB Number: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

institution’s Web site for prospective students to view. The Department does not store 

this information in any system resident at the Department.

Section 668 - Subpart A – General - §668.6 – Reporting and disclosure 

requirements for programs that prepare students for gainful employment in a recognized 

occupation. (OMB control number: 1845-0107)

In the regulations §668.6(b) Disclosures, for each program in this section, the 

institution must provide prospective students with the name of the occupations (by name 

and its Standard Occupational Classification (SOC) code) that the program prepares 

students to enter, along with links to occupational profiles on the Department of Labor’s 

Occupational Information Network (O*Net), or Web links to a representative sample of 

the SOC codes for which its graduates typically find employment. Institutions are also 

required to disclose on their Web sites information about on-time graduation rates for 

students completing the program; the cost of tuition and fees for these programs within 

normal time, the cost of books and supplies, and room and board, if applicable. The 

institution may include information on other costs, such as transportation and living 

expenses, but it must provide a Web link, or access to the program cost information the 

institution makes available under §668.43. 

The placement rate for students completing the program must be disclosed and the 

institution must identify whether the placement rate was calculated under the accrediting 

agency or the State’s requirements. In lieu of disclosing the accrediting agency or State 

required placement rates, an institution must disclose the placement rate as determined 

under a methodology that will be developed by NCES, when that rate is available. 

Additionally, the institution must separately identify the median loan debt from Title IV, 

HEA program loans incurred by students and the median loan debt from private loans and 

institutional financing plans. 

For each program, the institution must include the information in §668.6(b) in 

promotional materials it makes available to prospective students and post this information 

on its Web site. The information displayed on the institution’s Web site must be 

prominently displayed in an open format that can be retrieved, downloaded, indexed, and 

searched by commonly use Web search applications. An open format is one that is 

platform independent, machine readable, and made available to the public without 

restrictions that would impede the re-use of that information.

The Secretary provides a disclosure template that is accessible to institutions 

online through the Office of Postsecondary Education’s Web site. A Gainful 

Employment Disclosure Template Quick Start Guide (in two different browser formats) 

is also provided to assist institutions with completing the required disclosure template. 

The disclosure template was developed to provide institutions with a uniform format for 

the submission and collection of information required under §668.6(b) to be resident on 

the institution’s Web site for each of its gainful employment programs. Institutions will 

fill in required information from §668.6(b) in the designated sections of the disclosure 

template and will submit it after completion. Once the institution’s information has been 
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OMB Number: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

captured by the disclosure template, it will subsequently generate a file that must be 

saved and posted to the institution’s Web site. The file displays the information that 

institutions have input and information that has been supplied by the Department into the 

disclosure template in a standard format that can be used by institutions on their Web 

sites. A list of gainful employment disclosure definitions is provided in the disclosure 

template start up guide to assist institutions with completing the template successfully. 

The data elements on the disclosure template include, but are not limited to: an 

institution’s 6-digit OPEID, a program’s 6-digit CIP code, the credential level of the 

program, program length, total tuition and required fees for the entire program completed 

in normal time, total estimated costs for books and supplies for the entire program, total 

room and board charges for living on campus, the URL for program cost information on 

an institution’s Web site, the number of students completing the program, the median 

cumulative federal student loans debt, the median cumulative private loan debt, the 

median cumulative institutional financing plan debt, information on program completion 

in normal time, and job placement rate. Institutions will be required to provide additional 

information regarding their gainful employment program’s job placement rate including, 

but not limited to: who is included in the rate, what type of jobs, the timeframe of when 

the job placement rate is based, how graduates are tracked, and to what state or 

accrediting agencies, if any, that rate is reported. These data elements provided by

institutions to the Department will meet the disclosure final provisions required in 

668.6(b). 

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. 

Student Assistance General Provisions:

The Department of Education is responsible for evaluating whether students are 

receiving training in a recognized occupation where they can be gainfully employed. The 

information that will be disclosed by institutions for each of their gainful employment 

programs on the institution’s Web site is consistent with the regulations and will allow 

the institution and the Department to evaluate the outcomes of programs that lead to 

gainful employment in a recognized occupation, as well as, inform prospective students. 

The information provided by institutions on the disclosure template is required to

be prominently displayed on the institution’s Web site and accessible to prospective 

students as a resource. Institutions will save the disclosure template as the output 

document provided by the Department and display it on its Web site and any applicable 

programmatic Web site to insure a consistent look, which will make data comparison 

much easier and more effective for prospective students. 

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 
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OMB Number: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

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. 

There are no legal or technical obstacles to the use of technology in this 

information collection activity. 

This disclosure of information involves electronic submission of responses and 

Web technology through the use of the disclosure template that institutions are required 

to complete and by providing information to prospective students through an institution’s 

Web site. The disclosure template is hosted online through the Office of Postsecondary

Education and permits institutions to electronically submit their responses and receive 

information such as, but not limited to CIP codes in a drop-down listing for selection, 

credential level of programs in a drop-down listing for selection, Standard Occupational 

Codes (SOC codes) in a drop-down listing for selection. 

The information in §668.6(b) that is submitted by institutions using the disclosure 

template will not be collected and saved by the Department, but instead is be used to 

capture a “snapshot” of the institution’s data submitted at that time. Web technology is 

incorporated into this template consistent with the requirements of §668.6(b) so 

institutions can disclose information to students on the institution’s Web site. 

Prospective students will have the ability to compare gainful employment programs at 

different institutions and to learn what career options are available with each program 

before enrolling at an institution. 

Additionally, the output document will use the schema.org vocabulary, along with 

the microdata format, to add information to the HTML content that will make it easier for 

search engine users to locate the information about the programs when searching the 

Internet. 

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.

This information is not duplicated on any other information collection.

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.

The provisions of 668.6(b) will not have a significant economic impact on a 

substantial number of small entities. We have minimized burden on for these and all 

institutions by providing a format and some of the required data for the regulatory
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OMB Number: 1845-0107 Revised: 2/24/2015

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disclosures as well as a template to present the required information to prospective 

students.

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 disclosure of information about a gainful employment program on the 

institution’s Web site will provide useful information to prospective students and their 

families. The intent of the provisions in §668.6(b) is to enable students to make an 

informed choice about a gainful employment program by making the disclosures clear, 

timely, and meaningful. These disclosures will also allow students to make 

determinations about the amount of student indebtedness is being incurred by students 

who complete the gainful employment program, the average amount of the cost of 

attendance, normal completion time, and job placement data. 

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.

There are no special circumstances connected to this collection. 

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.
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OMB Number: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

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.

This collection will have both a 60 and 30 day period requesting interested parties 

to provide comments on the burden calculation for this format. This is the request for the 

30 day public comment period.

While no public comments were received during the 60 day comment period, 

there were internal discussions about comments received by the contractor from the 

institutional users of the disclosure template. Those comments have resulted in two 

minor changes to the template. These changes are illustrated on the attached two pages 

from the Quick Start Guide. 

The first change eliminates the need to check a box indicating there were few than 

10 graduates in a program and keeping the median loan debt from being calculated to 

preserve confidentiality of loan respondents. There is internal programming that 

recognizes when an institution has input fewer than 10 in the appropriate box and causes 

the median loan debt from being calculated and displayed. 

The second change adds a radio button to allow a school to indicate that there 

were no graduates in a specific program for a specific year. This provides greater clarity 

in the disclosure template by expanding the explanations of why no data was provided for 

job placement.

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

of contractors or grantees with meaningful justification.

There are no payments or gifts to respondents.

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

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

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

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

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

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

 

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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 –
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OMB Number: 1845-0107 Revised: 2/24/2015

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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.

There is no assurance of confidentiality provided to institutions for the submission 

of this information.

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.

There are no questions of a sensitive nature in this application.

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.

As stated earlier, in the recent negotiated rulemaking sessions regarding Gainful 

Employment, §668.6(a) – “Reporting requirements” was removed and reserved. 

Therefore, the burden previously identified in this information collection for that section 

of the regulations needs to be removed to correctly report the burden assessed to 

institutions and individuals.

 

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: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

# of Respondents # of Responses # Hrs

Burden

Current inventory:

 19,780,528 19,780,528 1,270,478

Remove burden assess for §668.6(a):

 16,274,929 16,274,929 668,758

New starting inventory:

 3,505,599 3,505,599 601,720

AFFECTED ENTITES and BURDEN: 

Individuals:

We estimate that 2,227,230 prospective students will enroll in gainful 

employment programs at proprietary institutions. On average, we estimate that it will 

take a student 10 minutes (.17 hours) to read the disclosures provided by the institution 

for a total of 378,629 hours of increased burden in OMB Control Number 1845-0107.

We estimate that 65,697 prospective students will enroll in gainful employment 

programs at private nonprofit institutions. On average, we estimate that it will take a 

student 10 minutes (.17 hours) to read the disclosures provided by the institution for a 

total of 11,168 hours of increased burden in OMB Control Number 1845-0107.

We estimate that 314,517 prospective students will enroll in gainful employment 

programs at public institutions. On average, we estimate that it will take a student 10 

minutes (.17 hours) to read the disclosures provided by the institution for a total of 

53,468 hours of increased burden in OMB Control Number 1845-0107.

Collectively, under §668.6(b), we estimate that it will take 2,607,444 prospective

students a total of 443,265 hours of burden to read the disclosures provided by the 

institution under OMB Control Number 1845-0107.

Institutions:

We estimate that there are 37,589 gainful employment programs at 3,961 

institutions that will require disclosure consistent with the requirements of §668.6(b). 

We estimate that there are 12,250 gainful employment programs at 2,526 

proprietary institutions that must comply with these disclosure requirements. On 

average, we estimate that it will take institutional staff 8 minutes (.13 hours) per program 

to complete the disclosure template as provided by the Department and disclose this 

information on the institution’s Web site for a total of 1,593 hours of burden in OMB 

Control Number 1845-0107.
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OMB Number: 1845-0107 Revised: 2/24/2015

RIN Number: XXXX-XXXX (if applicable)

We estimate that there are 2,343 gainful employment programs at 318 private 

nonprofit institutions that must comply with these disclosure requirements. On average, 

we estimate that it will take institutional staff 8 minutes (.13 hours) per program to 

complete the disclosure template as provided by the Department and disclose this 

information on the institution’s Web site for a total of 305 hours of burden in OMB 

Control Number 1845-0107.

We estimate that there are 22,996 gainful employment programs at 1,117 public 

institutions that must comply with these disclosure requirements. On average, we 

estimate that it will take institutional staff 8 minutes (.13 hours) per program to complete 

the disclosure template as provided by the Department and disclose this information on 

the institution’s Web site for a total of 2,989 hours of increased burden in OMB Control 

Number 1845-0107.

Collectively, under §688.6(b), we estimate that it will take institutional staff a 

total of 4,887 hours of burden in OMB Control Number 1845-0107 to complete the 

Department’s gainful employment template and disclose this information on the 

institution’s Web site.

Revised burden calculations for Section 668.6(b) – Disclosures:

# of # of # of 

 Respondents Responses Burden 

Hours:

INDIVIDUALS: 2,607,444 2,607,444 443,265

INSTITUTIONS

Proprietary: 2,526 12,250 1,593

Private Non-Profit: 318 2,343 305

Public: 1,117 22,996 2,989

Institution Sub-total:

 3,961 37,589 4,887

Revised Total for Disclosures:

 2,611,405 2,645,033 448,152

The revised burden hours were calculated at 601,702 and the newly assessed 

burden hours are 448,152 for a net decrease of 153,568 of burden hours. This change is 

due to the decrease in the number of programs required to complete the Department’s 

gainful employment template and disclose this information on the institution’s Web site 

as well as the number of prospective students estimated to begin those programs.

Attached is Chapter 2 of the “Gainful Employment Disclosure Template Quick State 

Guide” which includes screen shots of the web-based information collection disclosure 
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OMB Number: 1845-0107 Revised: 2/24/2015

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template, the output document to be displayed on the institution’s Web site and an 

explanation of data elements. 

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 : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

No costs have been associated with this revision.

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.

The estimate of annualized cost to the Federal government is $50,000 per year. 

The cost was provided as a contract estimate from the Office of Postsecondary Education.
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OMB Number: 1845-0107 Revised: 2/24/2015

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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 an extension of the current collection package and there is a decrease in 

the amount of burden in the current inventory. The burden change of 448,152 hours,

2,611,405 respondents and 2,645,033 responses are due to estimated decreases in the 

number of prospective students as well as a decrease in the estimated number of gainful 

employment programs that would require the regulatory disclosures. Additionally, due to 

the removal of a section of the regulations, a large number of burden hours (668,758) and 

respondents/responses (16,274,929) are also removed from the information collection.

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.

This information will not be published by ED.

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.

There are no exceptions to the certification.