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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Student Assistance General Provision – Subpart I – Immigration Status Confirmation

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.

This request is for approval of an extension of the reporting requirements currently in the 

Student Assistance General Provisions, 34 CFR 668, Subpart I. This subpart governs the 

Immigration-Status Confirmation, as authorized by section 484(g) of the Higher 

Education Act of 1965, as amended (HEA) (20 U.S.C. 1091). The regulations can be 

reviewed at 34 CFR 668, Subpart I.

This collection updates the usage by individuals and schools. This is necessary to 

determine eligibility to receive program benefits and to prevent fraud and abuse of 

program funds. 

The regulations in §668.133 identify when an institution must have a student produce 

documentation that supports their status as an eligible noncitizen as provided by the U.S. 

Department of Homeland Security’s (DHS) office of Citizenship and Immigration 

Services (USCIS) and when it must request DHS secondary confirmation of such 

eligibility through the use of the G-845 form. This is required if the student’s Title IV 

output document indicates that confirmation is needed or when confirmation is provided 

by DHS-USCIS, but the institution has conflicting information about the student’s status.

The regulations in §668.134 require an institution to have written policies and procedures 

for requesting proof from students and getting confirmation of eligibility for Title IV 

funds. The regulations also specify that the institution provide in writing to each student 

required to undergo secondary confirmation a clear explanation of the documents that 

must be submitted for eligibility confirmation as well as a clear explanation of the 

student’s responsibilities including deadlines and consequences of failing to complete the 

required actions.

 

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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

The regulations in §668.135 require an institution to have procedures for completing the 

manual secondary confirmation of eligibility for Title IV funds for eligible noncitizens 

that did not have their eligibility determined through the automated confirmation process. 

While the regulation discusses the completion of the G-845, the burden estimate here is 

limited to the copying of the supporting documents to be submitted with the G-845. It 

does not include the burden assessment already calculated by DHS USCIS.

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.

Requiring institutions to have processes for the collection and confirmation of this 

student information enables the Secretary to determine if a noncitizen applicant for Title 

IV, HEA benefits is an eligible student as defined in section 484(a)(5) of the HEA. The 

ability to make this determination reduces the potential for fraud and abuse in the Title 

IV, HEA programs caused by ineligible aliens receiving Federal student financial 

assistance. By reducing the potential for fraud and abuse, the Secretary is better able to 

safeguard Federal student financial aid dollars for the intended purpose of providing 

educational opportunities to U.S. citizens or noncitizens with Title IV, HEA eligible 

immigration credentials.

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 Secretary uses an automated data matching system in conjunction with the 

Department of Homeland Security’s (DHS) office of Citizenship and Immigration 

Services (USCIS) to electronically confirm the eligible noncitizen status of a noncitizen 

applicant for Title IV, HEA benefits. The data matching system is operated in full 

compliance with the Computer Matching and Privacy Protection Act of 1988 (CMPPA), 

as amended in order to prevent fraud and abuse. As required by the CMPPA, applicants 

with immigration statuses that are not confirmed as eligible noncitizens by the data 

matching system are not presumed to be ineligible and are instead, subject to a secondary

automated confirmation process within USCIS. In those limited cases where 

confirmation is not achieved after the automated secondary confirmation, the noncitizen 

applicant is subject to a manual secondary confirmation process requiring the institution 

to request written confirmation from USCIS through the submission of a G-845 Form (as 

provided by USCIS), along with copies of the student’s immigration status 

documentation that has been already provided to the institution by the applicant. The 

elements of this additional process (except for the completion and submission of the G845 form, which is approved under OMB 1615-0101 through the U.S. Department of 

Homeland Security), which we refer to as manual secondary confirmation, constitutes the 

information collection for which we are requesting continued approval.
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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

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 duplication of records or similar information already available for use by 

institutions.

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 information collected does not involve small business entities.

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 this information is not collected or is collected less frequently, the potential for fraud 

and abuse increases. Also, section 484(g)(1) provides that the Secretary will verify

applicant claims of citizenship or eligible noncitizen status prior to awarding grants, loans 

or work assistance under Title IV of the HEA. The provision precludes the Secretary

from employing any procedure that does not verify U.S. citizenship or eligible 

immigration status of all applicants for Title IV, HEA benefits.

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
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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

 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.

Under 34 CFR 668.135, an institution that receives immigration status documents from a 

student with an immigration status that was not confirmed using the USCIS/ED data match 

or the automated secondary confirmation process is required to request written confirmation 

from the USCIS within 10 business days.

No institution is required to submit more than the original completed G-845 Form and one 

copy of any USCIS immigration status document(s).

No institution is required to retain immigration status records for more than three years after 

the end of the award year for which the Title IV, HEA aid was awarded and disbursed.

This information collection does not include a statistical survey or use of a statistical data 

classification.

This information collection does not include a pledge of confidentiality that is not supported 

by authority established in statute or regulation, is not supported by disclosure and date 

security policies consistent with the pledge, or which impedes sharing of data with other 

agencies.

This information collection does not require respondents to submit proprietary trade secrets 

or other confidential information.

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.

This information collection is not in conjunction with negotiated rulemaking. Consultations 

with the USCIS are conducted approximately twice yearly and more often if needed – these 

consultations are useful in addressing interagency processing problems and in discussing 

how new technologies can be employed to perform these functions more efficiently. 
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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

Automated secondary confirmation as provided by USCIS has significantly reduced the 

percentage of non-matches that lead to the required data collections and submission of the G845 Form to USCIS. There were no comments received during the 60 day comment period. 

This filing is for the 30 day comment period. 

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

of contractors or grantees with meaningful justification.

There is no payment or gift 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.

These requirements do not prescribe any assurance of confidentiality to institutions except as 

required under the provisions of the CMPPA.

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.

These regulations do 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. 

 

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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 Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

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.

Total Current Inventory:

# of Respondents # of Responses Burden Hours

77,375 143,332 17,917

Revised Inventory:

Of the 926,582 applications from noncitizen applicants processed in the 2013-2014 award 

year, 131,248 were not confirmed using the data matches (automatic primary or automatic 

secondary) and required additional information to confirm Title IV eligibility. Of the 

131,248 applications, 117,265 would require the financial aid administrator to send a 

completed G-845 to DHS for secondary confirmation of eligibility. The 117,265 are reduced 

by 25% to 87,949, as an estimated number of students who will begin enrollment and 

therefore utilize the Title IV programs is 75% of non-confirmed applicants.

The 25% or 29,316 possible Title IV eligible applicants either dropped out of the application 

process or were not subject to manual secondary confirmation because of the regulatory

provisions in 34 CFR 668.133(b) that exempt respondents from this requirement if such 

confirmation was successfully used to confirm a student’s eligible noncitizen status in the 

previous award year. 

Revised Inventory – by affected entity

# of Respondents # of Responses X Hours/ = Burden

Response Hours

Individuals:

 87,949 87,949 .08 hours = 7,036

(5 minutes)

For-profit institution:

2,151 30,701 .17 hours = 5,219
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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

(10 min.)

Not-for-profit institution:

1,811 25,848 .17 hours = 4,394

(10 min.)

State, local or Tribal entities

2,200 31,400 .17 hours = 5,338

(10 min.)

Total Revised Inventory

# of Respondents # of Responses Burden Hours

 94,111 175,898 21,987

Difference from previous to proposed new inventory

# of Respondents # of Responses Burden Hours

 16,736 32,566 4,070

These figures do not include the USCIS calculated burden of 5 minutes for the completion 

and submission of the G-845 for OMB # 1615-0101.

The annual cost burden attributable to institutional staff is as follows:

$6.21 respondent salary cost ($36.55/hr. x 15 min)

X 21,987 estimated annual frequency

= $ 136,539

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.
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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

 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) : $ 0.49 Postage

+ $ 0.75 Photocopying and student interview

X 21,987 Estimated annual frequency

Total Annualized Costs Requested: =$ 27,264 estimated cost to respondents

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.

ED’s CPS Processing Costs

 926,582 Records sent to DHS

X $0.01 Processing cost per record

= $9,266 Application processing

ED’s Correction Processing Costs

 117,265 No match records

X 0.25 Percent returning as corrections

X .084 Cost per record for history correction reprocessing

= $2,466 History correction reprocessing

Cost to ED

 $9,266 Application processing

+ $2,466 History correction reprocessing

+ $11,110 Leased phone lines

+ $50,217 ED administration costs

= $73,059 Estimated total annual cost to ED

Total estimated cost to government is $73,059.

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 
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OMB Number: 1845-0052 Revised: 2/3/2015

RIN Number: XXXX-XXXX (if applicable)

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 OMB information collection number 1845-0052. There 

is an increase of 4,070 burden hours due to an increase in the number of respondents who 

need to present documentation to the school to be included with the G-845 form to complete 

the confirmation of eligibility to receive Title IV assistance. There has not been any change 

to the regulatory language requiring this activity.

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.

There are no plans to publish the results of this information collection.

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 of Education is not seeking approval not display the expiration date for 

OMB approval.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The Department of Education is not seeking an exception to the certification for Paperwork 

Reduction Act submissions.