1

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable)
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **The William D. Ford Federal Direct Loan Program Federal Direct PLUS Loan** 

**Request for Supplemental Information 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 appropriate section of each statute and regul ation 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 with 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. Section 455(a) of the Higher Education Act of 1965, as amended (the HEA) authorizes Federal Direct PLUS L oans (Direct P LUS Loans) as one of the loan t yp es that are available through the William D. Ford Federal Direct Loan Program (Direct Loan Program). Direct PLUS Loans are made to parents of dependent undergraduate students and to graduate and professional students. In accordance with 34 CFR 685.201(b), a parent or a graduate or professional student who wishes to borrow a Direct PLUS Loan must complete a Direct PLUS Loan Master Promissory

Note (Direct PLUS Loan MPN; approved under OMB No. 1845

- 0068)). A master promissor y note is a promissory note under which a borrower may receive loans for a single academic year or multiple academic ye ars (see the definition of “master promissory note” in 34 CFR 685.102(b)). Borrowers have the option of completing a paper Direct PLUS L oan MPN or completing the Direct PLUS L oan MPN electronically on ED’s StudentL oans.gov web site. The eligibility requirements for Direct PLUS Loan borrowers are in 34 CFR 685.200(b) and (c). Schools that participate in the Direct Loan Program are responsi ble for determining a borrower’s eligibility

for a Direct PLUS Loan and must submit an electronic loan origination record to the U.S. Department of Education (ED) for each Direct PL US Loan that a borrower receives. The loan origination record includes loa n - specific information that is not included on the Direct PLUS Loan MPN, such as the loan amount. Because the Direct PLUS Loan MPN is a multi

- year promissory note that can be used to make multiple loans for up to 10 years, it is not possible to include on the MPN itself loan

- specific information about the multiple individual loans that may

be made under a single Direct PLUS L oan MPN. The Direct PLUS Loan Request for Supplemental Information (Direct PLUS L oan Request) collects additional information that schools need in order to originate Direct PL US Loans. Schools obtain this information through the currently approved Direct PLUS Loan Request (1845

- 0103) or directly from Direct PLUS L oan applicants through school

- based procedures that they

have developed and that vary from school to school. The form has been reorganized and streamlined to make it easier for PLUS borrowers to use.

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

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable)
2. Indicate how, by

whom, and for what purpose the information is to be used. Except for a new collection, indicate the act ual use the agency

has made of the information received from the current collection. The Direct PLUS Loan Request collects information that is required by schools before they can originate a Direct PLUS Loan. The Direct PLUS Loan Request also provides Direct PLUS Loan applicants with options for completing certain actions related to their loans (for example, requesting a deferment) that would otherwise have to be completed by other means. This reduces burden on borrowers by allowing them to complete mu ltiple actions as part of the Direct PLUS Loan Request process instead of having to complete multiple separate transactions. ED developed the Direct PLUS Loan Request in response to requests from schools that participate in the Direct Loan Program. The pr incipal purpose of the Direct PLUS Loan Request is to simplify

the Direct PLUS Loan application process for borrowers and assist schools in the creation of Direct PLUS Loan awards. S chools wanted to have a standardized process for collecting some of the i nformation needed for a Direct PLUS Loan origination record that is not collected on the Direct PLUS Loan MPN. In addition, schools wanted this information to be collected on the same ED web site where borrowers may complete an electronic Direct PLUS Loan MPN and Direct Loan entrance and exit counseling, so that parents and students will be able to go to a single location where they can provide the information needed by schools to originate a Direct PLUS Loan, complete a Direct PLUS MPN (if they have not a lread y done so) and, if required, entrance counseling. The Direct PLUS Loan Request is only available electronicall y on ED’s StudentL oans.gov web site. A paper option is not available. Completion of the Direct PLUS Loan Request is optional, at the discre tion of the school that is awarding a borrower’s Direct PLUS Loan. Schools may continue to use their own procedures to obtain the information needed to originate Direct PLUS L oans, or they may direct parent and student Direct PLUS Loan borrowers to ED’s w eb site to complete ED’s Direct PLUS Loan Request. If a school chooses to use ED’s Direct PLUS Loan Request, a borrower will have to complete a Direct PLUS Loan Request for each Direct PLUS Loan that he or she receives. A borrower accesses the Direct PLU S Loan Request on the same ED web site where a borrower may

complete an electronic PLUS MPN or complete Direct Loan electronic entrance and exit counseling. To access this web site, a borrower must have a Federal Student Aid PI N. Once a borrower has compl eted a Direct PLUS Loan Request, ED will transmit the information that the borrower provided to the school(s) that the borrower identified. 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 Direct PLUS Loan Request makes maximum use of available information technology . A borrower must have a Federal Student Aid PI N to access the web site where the Direct PLUS Loan Request is located. Identify ing inf ormation from the PIN web site3

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable) automatically

populates some of the Borrower Information data elements on the Direct PLUS Loan Request, so the borrower does not have to provide this information. In addition, if a borrower who is completing the Direct PLUS Lo an Request has alread y completed a Direct PLUS Loan MPN, or has another record on file in ED’s Common Origination and Disbursement Sy stem (for example, a Pell Grant origination record), most of the additional data elements in the Direct PLUS Loan Request for Supplemental Information are automatically populated based on the existing information from the Direct PLUS Loan MPN or other record. Borrowers are onl y required to provide information that is not already available from existing records, or make an y necessary corrections to the information that is imported from other records. If a borrower who completes the Direct PLUS Loan Request has not already completed a Direct PLUS Loan MPN, the information collected on Direct PLUS Loan Request is used to popul ate corresponding data elements on the Direct PLUS L oan MPN when the borrower completes that document. 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 th e purposes described in I tem 2 above. The Direct PLUS Loan Request does not require borrowers to provide information that is available from other records maintained b y ED. There is no information available from other sources that can be used for the purp oses described in I tem 2. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not - for

- profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a g overnment 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 activiti es if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. Completion of the Direct PLUS Loan Request is optional, at the discretion of the school that is processing a borrower’s Direct PLUS Loan request. If a school wants its Direct PLUS Loan applicants to complete ED’s Direct PLUS Loan Request, a borrower will have to complete a separate Direct PLUS Loan Request for each Direct PLUS L oan that he or she receives. If a borrower did not complete the Direct PLUS Loan Request, the school would have to obtain some of the information that is included in the Direct PLUS L oan Request by other means. 7. Explain any

special circumstances that would cause an information collection to be conducted in a manner:4

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable)

 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, other 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 ;  requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;  that includes a pledge of confidentiality that i s 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 confiden tial 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 conditions listed 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 infor mation collection prior to submission to OMB. Summarize public comments received in response to that notice and 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 consultation in a specific situation. These circumstances should be explained. The currently

approved Direct PLUS Loan Request was developed at the request of schools that participate in the Direct Lo an Program. The form has been reorganized based upon feedback from the scho ols. The clearance process which provide s the public with two opportunities to submit comments on the revised forms included with this submission has been completed
. No public comments have been received during the 60

- day period. A 30
- day notice will be published in the Federal Register. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful ju stification
.5

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable) No pay ments or gifts will be provided to 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 Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated o n the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confide ntiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. The Direct PLUS Loan Request includes a Privacy Act Notice that (1) provides the statutory authorit y for the i nformation collection, (2) explains that disclosure of the information is voluntary , and (3) identifies the third parties to whom the information may be disclosed, and explains the circumstances under which such disclosures may occur. 11. Provide addition al justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y t he 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. The Direct PLUS Loan Request does not require respondents to pro vide any information that would be considered sensitive. 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 hous eholds, 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 iden tification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain 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

2 Requests for this information are in accordance with the follow ing ED and OMB policies: Privacy Act of 1974, OMB Circular A

- 108

– Privacy Act Impleme ntation

– 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)6

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable)

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 h our 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, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outside parties for information collection activities should not be included here. Instead, this cost should be included in I tem 14. ED estimates the total annual number of respondents for this information collection to be approximately

1,230,000. The estimated time required to complete a Direct PLUS L oan Request is 0.5 hours hour (30 minutes). Based on one response per respondent, this equates to a total estimated annual reporting burden of 615,000 hours. 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 burde n shown in I tems 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 us eful 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; monitori ng, 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 the reasons for the variance. The cost of cont racting 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 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 o r 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 :7

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable) Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : There are no capital/startup costs to respondents, nor are there any annual costs to respondents associated with o perating or maintaining s ys tems or purchasing services. 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 expense s (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 I tems 12, 13, and 14 in a single table. The tot al estimated annual cost to the Federal government for this information collection is $1,327,890.00. This includes costs associated with software development and electronic transmission/receipt of data. 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 respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion) , ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include tot als for changes in burden hours , responses and cost s (if applicable)
. This is a request for a revision of the currentl y approved form. The form was reorganized for improved usability

and flow. No changes are being proposed to the 615,000 burden hours due to this reorganization. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. The results of this information collection will not be published. 17. If seeking approval to not display the expiration dat e for OMB approval of the information collection, explain the reasons that display would be inappropriate. ED is not seeking this approval.8

EDICS Tracking and OMB Number: ( 1467 ) 1845
- 0103 Revised: 0 6 / 1 9 / 2014 RIN Number: XXXX

- XXXX (if applicable) 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

- I.