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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Pre-Authorized Debit Account Brochure and Application

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 Preauthorized Debit Account (PDA) payment option allows individuals with 

defaulted federal education debts (student loans or grant overpayments) held by the 

U.S. Department of Education’s (ED’s) Federal Student Aid Default Resolution Group to 

have their payments automatically debited from their checking or savings accounts and 

sent to ED. Individuals who choose the use the PDA option to make their payments must 

authorize ED to debit their bank accounts. The PDA Brochure and Application (PDA 

Application) explains the PDA payment option and collects the applicant’s authorization 

for electronic debiting of payments and the bank account information needed by ED to 

debit the applicant’s account. This automatic debiting process will continue through the 

full repayment of the debt or until the individual contacts the ED Default Resolution 

Group to cancel this service. 

The authority for the PDA option is provided under the Deficit Reduction Act of 1984, 

P.L. 98-368, and 31 C.F.R. 202, Depositaries and Financial Agents of the Government. 

Operating rules and regulations approved and published by the National Automated 

Clearing House Association (NACHA) and 31 C.F.R. 210 also govern the use of the PDA 

Application. Finally, Regulation E, issued and maintained by the Board of Governors of 

the Federal Reserve System, implements Title IX of the Consumer Credit Protection Act, 

as amended in 15 U.S.C. 1601. This regulation is designed to implement the act, which 

primarily serves to protect the interests of the individual consumer participating in 

electronic transfers.

ED is requesting an extension of the currently approved collection with no changes to 

the form or format. 

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.

 

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Please limit pasted text to no longer than 3 paragraphs.
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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

Any individual included in the ED Default Resolution Group’s database who is in a

voluntary payment status may choose to have their debt payments made through the 

PDA option. Individuals who wish to use the PDA payment option must complete the 

PDA Application and return it to ED with the required documentation.

ED then uses the information collected on the approved PDA Application, along with the 

required documentation, to establish electronic debiting for individuals who have 

requested to have their defaulted federal education debt payments debited from their 

bank accounts. The PDA Application will continue to be used for this purpose. 

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

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

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

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

technology to reduce burden.

This collection of information involves the use of automated and electronic technology 

in order to provide the most convenient means for an individual to repay a defaulted 

federal education debt. The benefit of this payment option is that the required payment 

amount is automatically debited from the individual’s checking or savings account. This 

reduces burden on the individual, since he or she does not have to write a check every 

month or spend money on postage. In addition the PDA option ensures that payments 

will always be made on time

Debited funds are electronically transmitted to the U.S. Treasury. The U.S. Department 

of the Treasury’s Financial Management Service in Kansas City (FMS-KC) transmits data 

regarding these transactions to ED and the payment information is posted to individual 

accounts.

Because the application requires a signature and accompanying documentation the 

application process remains paper-based.

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2 above.

There is no information 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.
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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

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.

If ED did not collect the data requested in the PDA Application, we would not have the 

information needed to implement the PDA payment option. The PDA option provides a 

more convenient and less burdensome means for individuals with defaulted federal 

education debts to make their payments and helps to ensure that payments are made 

on time. 

Generally, an individual is required to complete a PDA Application only one time. An 

individual may be required to complete a PDA Application more than once if (1) banking 

information changes or (2) the individual was participating in the PDA option, stopped 

participating, and then wants to participate in the PDA option again.

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

in a manner:

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

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

fewer than 30 days after receipt of it;

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

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

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

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

results than can be generalized to the universe of study;

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

approved by OMB;

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

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

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

agencies for compatible confidential use; or

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

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

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

This information collection does not involve any of the conditions listed in 5 CFR 

1320.5(d)(2).
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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

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.

In developing the current PDA Application, ED consulted with our contractor that deals 

directly with PDA applicants and processes the applications. The clearance process 

provides the public with two opportunities to comment on the revised PDA Application 

during comment periods announced by notices published in the Federal Register. This is 

the 60-day notice for public comment. There will also be a 30-day public comment 

period. 

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 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.

 

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

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

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

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

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

of Personally Identifiable Information)
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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

The form includes a Privacy Act Notice that (1) informs applicants of the statutory 

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

voluntary, but is required if the applicant wishes to have payments made through the 

PDA option, and (3) identifies the third parties to whom the information may be 

disclosed, and explains the circumstances under which such disclosures may occur. 

In addition, the assurance of confidentiality is stated in the Memorandum of 

Understanding (MOU) between ED and Treasury, and by contract between ED and its 

contractor.

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.

This collection does not include any questions of a sensitive nature.

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

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

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

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

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

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

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

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

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

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

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

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

not include burden hours for customary and usual business practices.

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

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

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

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

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

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

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

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

14.

The total estimated annual hour burden for this collection is 133 hours. The hour burden 

and cost estimates were calculated as follows:
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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

Estimated annual number of 

respondents:

 1,600

Number of responses per borrower: x 1

Hours per response: x 0.083 (5 minutes)

Annual hour burden: 133 hours

The previous annual number of respondents and responses was 1,600 x 0.083 hour for a 

total of 133 burden 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 : 0

Total Annual Costs (O&M) : 0

____________________

Total Annualized Costs Requested : 0

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.
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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 $170,000 for the collection 

and processing of the data by ED’s data by FMS-KC. Estimated annualized cost is based 

upon the maximum support personnel needed to do the initial input processing of the 

preauthorized debit application information that will be submitted to FMS-KC for

Electronic Funds Transfer (EFT), any computer processing and the monthly maintenance 

and routing to the Federal Reserve Bank. This estimated cost also includes the amount 

ED pays to its contractor under the terms set forth in the contractual agreement to 

service and maintain its portfolio of defaulted loans.

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 an extension of the current information collection. There is no 

anticipated adjustment in respondents or hours. The burden estimate for completion 

and submission of the application remains 5 minutes per applicant.

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 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.
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OMB No. 1845-0025 Revised: 04/23/2015

RIN Number: XXXX-XXXX (if applicable)

ED is not requesting any exceptions to the “Certification for Paperwork Reduction Act 

Submissions” of OMB Form 83-I.