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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

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 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) of the Higher Education Act of 1965, as amended (the HEA) authorizes 

Federal Direct PLUS Loans (Direct PLUS Loans) as one of the loan types 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 

promissory note is a promissory note under which a borrower may receive loans for a single 

academic year or multiple academic years (see the definition of “master promissory note” in 34 

CFR 685.102(b)). Borrowers have the option of completing a paper Direct PLUS Loan MPN or 

completing the Direct PLUS Loan MPN electronically on ED’s StudentLoans.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 responsible 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 PLUS Loan that a borrower 

receives. The loan origination record includes loan-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 Loan MPN.

The Direct PLUS Loan Request for Supplemental Information (Direct PLUS Loan 

Request) collects additional information that schools need in order to originate Direct PLUS 

Loans. Schools obtain this information through the currently approved Direct PLUS Loan 

Request (1845-0103) or directly from Direct PLUS Loan 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.

 

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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

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 actual 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 multiple 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 principal 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. Schools wanted to have a standardized process for 

collecting some of the information 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 already done so) 

and, if required, entrance counseling.

The Direct PLUS Loan Request is only available electronically on ED’s 

StudentLoans.gov web site. A paper option is not available. Completion of the Direct PLUS 

Loan Request is optional, at the discretion 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 Loans, or they may direct parent and student Direct PLUS Loan 

borrowers to ED’s web 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 PLUS 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 PIN. 

Once a borrower has completed 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 any 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 PIN to access the web site where the 

Direct PLUS Loan Request is located. Identifying information from the PIN web site 
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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

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 Loan Request has already completed a Direct 

PLUS Loan MPN, or has another record on file in ED’s Common Origination and Disbursement 

System (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 only 

required to provide information that is not already available from existing records, or make any 

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 

populate corresponding data elements on the Direct PLUS Loan MPN when the borrower 

completes that document.

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 Direct PLUS Loan Request does not require borrowers to provide information that is 

available from other records maintained by ED. There is no information available from other 

sources that can be used for the purposes described in Item 2.

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.

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 Loan 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 Loan Request by other means.

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

in a manner:
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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

RIN Number: XXXX-XXXX (if applicable)

 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 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 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 currently approved Direct PLUS Loan Request was developed at the request of 

schools that participate in the Direct Loan Program. The form has been reorganized based upon 

feedback from the schools. The clearance process which provides 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 payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.
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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

RIN Number: XXXX-XXXX (if applicable)

No payments or gifts will be 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 Direct PLUS Loan Request includes a Privacy Act Notice that (1) provides the 

statutory authority for the information 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 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.

The Direct PLUS Loan Request does not require respondents to provide 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 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 

 

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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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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

RIN Number: XXXX-XXXX (if applicable)

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 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 Loan 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 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 : 
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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

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 operating or maintaining systems 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 

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 total 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 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 currently 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 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.
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EDICS Tracking and OMB Number: (1467) 1845-0103 Revised: 06/19/2014

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 any exceptions to the “Certification for Paperwork Reduction Act 

Submissions” of OMB Form 83-I.