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EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (if applicable)
**SUPPORTING STATEMENT**

**FOR PAPERWORK REDUCTION ACT SUBMISSION**

**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 regulation 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 collectio n (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(d) of the Higher Education Act of 1965, as amended (the HEA) requires the Secretary to offer William D. Ford Federal Direct L oan (Direct Loan) Program borrowers a choice of several plans for repay ing their loans. The Direct Loan Program regulations require borrowers to notify us of their initial repay ment plan selection in writing (see 34 CFR 685.210(a)(1)). Borrowers may change repay

ment plans after their loans enter repay ment by notify ing us; this notification need not be in writing (see 34 CFR 685.210(b)(1)). The Repay

ment Plan Selection form serves as the means by which Direct Loan borrowers notify us of their choice of an initial repay ment plan before their loans enter repayment. The form may also be used b y borrowers to request a change in repayment plans a fter their loans have entered repay ment. If a borrower does not select an initial repay ment plan, the borrower is placed on the Standard Repay

ment Plan in accordance with 34 CFR 685.210(a)(2). 2. Indicate how, by

whom, and for what purpose the informatio n 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 Department has used the collection of information on the currentl y approved Repayment Plan Selection form to obtain repay ment plan selection information from Direct Loan borrowers. The collection of information on the revised Repayment Plan Selection form in this clearance package continues to be necessary and will be used for the same purpose.

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

EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (if applicable) 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collecti on 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 De partment continues to maximize the use of available information technology in making and servicing Direct Loans. Direct Loan borrowers may complete and submit the Repay ment Plan Selection form electronically through their servicer’s web site or over the p hone. Currentl y, the overwhelming majority of borrowers do so. 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 the purposes described in Item 2 above. T here is no similar information alread y 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 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 government 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 th is information collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. Borrowers are asked to co mplete the Repay ment Plan Selection form only once, when they

are selecting an initial repayment plan prior to entering repay ment on their loans. If a borrower does not complete the Repayment Plan Selection form, the borrower is placed on the Standard Rep ay ment Plan, in accordance with the Direct Loan Program regulations. Borrowers may optionally

use the Repayment Plan Selection form to change repay ment plans at a later date. 7. Explain any

special circumstances that would cause an information collecti on to be conducted in a manner:

 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;3

EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (if applicable)

 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 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 unnecessaril y i mpedes sharing of dat a 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 confide ntiality 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 information 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 r eceived 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 i nformation 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 public has alread y had one opportunity to comment on the collection duri ng the 60 - day comment period. The Department received no comments. The public will have another opportunity

to comment on the collection during the 30 - day comment period. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification .4

EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (if applicable) No pay ments or gifts were or 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 on 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 suffi cient with respect to confidentiality . 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 repay ment plan request form includes a Privacy Act Notice that (1) informs the respondent of the statutory

authorit y for the information collection; (2) explains that disclosure of the requested information is voluntary , but is required in order for the request to be processed; and (3) identifies the third parties to whom the inform ation may be disclosed, and explains the circumstances under which such disclosures may occur. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that ar e 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. This information collection does not request an y s ensitive information. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of responden ts by affected public ty

pe (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 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, o r 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 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 I dentifiable Information)5

EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (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, prov ide separate hour burden estimates for each form and aggregate the hour 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 Item 14. Estimated annual number of respondents: 660,000 Number of responses per borrower: x 1 Hours per response: x 0.167 (10 minutes) Annual hour burden: 110,220 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 sp lit 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 useful life of capital equipment, the discount rate(s), and th e 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 widel y, 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 par t 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 existing6

EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (if applicable) economic or regulatory

impact anal ys is as sociated 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 inc lude the hourly costs (i.e., the monetization of the hours) captured above in Item 12 There are no costs to respondents associated with this collection. 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. There is no significant annualized cost to the Federal government. For the Direct Loan Program, the government’s contracts with its Direct L oan servicers is not bas ed on a fee - for - service model ; rather, the Department pay s its servicers based on performance metrics. The government incurs no additional cost merel y as a result of this information collection. 15. Explain the reasons for an y program changes or adjustme nts. 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 disag gregated 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 totals for changes in burden hours , responses and cost s (if applicable) . ED is not reporting an y changes in the burden hour estimate. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any comp lex 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 collecti on of information will not be published.7

EDICS Tracking and OMB Number: ( 1395.21 ) 1845 - 0014 Revised: 9/26/2013 RIN Number: N/A (if applicable) 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. The Department is not seeking this approval. 1 8. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the Certification for Paperwork Reduction Act Submissions of OMB Form 83 - 1.