### 1

OMB Number: 1845
- 0001 Revised: 10/22/2013

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION** 

**A. Justification 1. Explain the circumstances that m**  **ak e the collection of inform**  **ation 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 inform**  **ation ,**  **or you m**  **ay provide a**  **valid URL**  **link or paste the applicable section 1**  **. Specify the review type of the collectio n (new, revision,**  **extension, reinstatement with change, reinstatem ent without change)**  **. If revised, briefly specify the changes. If a rulem**  **aking is involved, make note of the sections or changed sections, if applicable.** Public Law 89 - 329, Sections 401 - 495 , the Higher Education Act of 1965, as amended (HEA), mandates that the Secretary of Education “... shall produce, distribute, and process free of charge common financial reporting forms as described in this subsection to be used for application and reapplication to determine the need and eligibility of a student for financial assistance. .. ” . The determination of need and eligibility are for the following Title IV, HEA, federal student financial assistance programs: the Federal Pell Grant Program; the Campus - Based programs (Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work - Study (FWS), and the Federal Perkins Loan Program); the William D. Ford Federal Direct Loan Program; the Teacher Education Assistance for College and Highe r Education (TEACH) Grant ; and the Iraq and Afghanistan Service Grant. Federal Student Aid, an office of the U.S. Department of Education (hereafter “the Department”), subsequently developed an application process to collect and process the data necessary to determine a student’s eligibility to receive Title IV, HEA program assistance. The application process involves an applicant’s submission of the Free Application for Federal Student Aid (FAFSA). After submission and processing of the FAFSA, an applic ant receives a Student Aid Report (SAR), which is a summary of the processed data they submitted on the FAFSA. The applicant reviews the SAR, and, if necessary, will make corrections or updates to their submitted FAFSA data . Institutions of higher educat ion listed by the applicant on the FAFSA also receive a summary of processed data submitted on the FAFSA which is called the Institutional Student Information Record (ISIR). The specific questions that applicants are asked to answer in the application process are described separately in the Data Elements and Justification document. The document lists all the data elements and explains the purpose and use of each in the application. In addition to calculation of financial need for t he various Title IV programs, the FAFSA also collects data that allows for a determination of a n applicant’s eligibility for state and school financial aid programs. If these data elements were not collected, the Department and institutions of higher educ ation would be unable to make a determination of financial need and subsequently would be unable to award any Title IV, HEA program assistance, as mandated by the HEA. A majority of S tates would also be greatly hindered in their calculation of S tate aid t o applicants . Important c hanges to the FAFSA are described separately in the 2014 - 2015 Enhancements to the Free Application for Federal Student Aid document. **2. Indicate how, by whom , and for what purpose the inform**  **ation is to be used. Except for a new collection,**  **indicate the actual use the agency has m ade of the information received from** **the current collection.**

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

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OMB Number: 1845
- 0001 Revised: 10/22/2013 The purpose of the application is to collect personal and financial data from current or prospective students in order to perform a need ana lysis as described in Part F of the HEA. The application is available in both English and Spanish and the main options for completing a FAFSA include (more specific application options are described in Question 12): 1) FAFSA on the Web (FOTW) submissions – Applicants can complete the online version of the FAFSA which offers a customized experience; 2) Financial Aid Administrator submissions – On behalf of the applicant, this option describes the electronic submission of a FAFSA by a designated third party (e.g ., the Department’s FAA Access system or a postsecondary institution’s mainframe computer); 3) Paper submissions – Applicants can complete and submit the paper version or the PDF version of the FAFSA; these versions must be mailed to the Department for proce ssing; or As required by Section 483 of the HEA, for applicants that have previously submitted a FAFSA, there is a Renewal FAFSA that retains certain static data and the applicant only needs to update information that has changed since the previous FAFSA submission. The Renewal FAFSA is offered within FOTW and to applicants who submit with the assistance of a financial aid administrator. The information an applicant is required to provide on the FAFSA varies based upon the need analysis formula that is b eing utilized. There are three need analysis formulas, the first is for dependent students (this formula also requires parental data), the second is for independent students without dependents other than a spouse, and the third formula is for independent students with dependents other than a spouse. After the application is completed, the applicant submits the form to the Department and the data is processed by the Department’s Central Processing System (CPS). The need analysis results in an expected fa mily contribution (EFC), which is an index used by postsecondary educational institutions and States when determining the types and amounts of both federal and non - federal financial aid students will receive. The EFC is calculated in accordance with the s tatutory formula in Part F of the HEA and is intended to indicate a student’s ability (and for dependent applicants, his or her family's ability) to contribute toward the student's cost of attending a postsecondary educational institution. The following c omponents are considered in the need analysis formula to determine the EFC: 1) The available income of (A) the independent student and (if married) the independent student's spouse, or (B) the dependent student and the dependent student's parents; 2) The numb er of dependents in the family of the student; 3) The number of dependents in the family of the student (excluding the parents) who are enrolled or accepted for enrollment, on at least a half - time basis, in a degree, certificate, or other program leading to a recognized educational credential at an institution of higher education that is an eligible institution in accordance with the provisions of Section 102 of the HEA and for whom the family may reasonably be expected to contribute to their postsecondary edu cation; 4) The net assets of (A) the independent student and (if married) the independent student’s spouse, or (B) the dependent student and the dependent student's parents; 5) The marital status of the student; 6) The age of the older parent, in the case of a depe ndent student; and 7) Any additional expenses incurred (A) in the case of a dependent student, when both parents of the student are employed or when the family is headed by a single parent who is employed, or (B) in the case of an independent student, when t he student is married and the student's spouse is employed or when the employed student qualifies as a surviving spouse or as a head of household under Title 26, Subtitle A, Chapter 1, Subchapter A, Part I, Section 2 of the Internal Revenue Code of 1986. The need analysis formula used to determine an EFC change s in order to simplify the application for families who meet specific conditions. The HEA specifies a Simplified Needs Test (SNT) for calculating the EFC for families who meet the requirements of Se ction 479 of the HEA . The SNT applies to families who have adjusted gross incomes less than $50,000 per year, and who meet at least one of the following eligibility requirements: 1) As defined in Section 479(b)(1) of the HEA, have filed or are eligible to file a n I nternal R evenue S ervice (IRS) F orm 1040A or 1040EZ; or 2) The independent student, independent student’s spouse, or the dependent student's parent(s) received benefits in the last 24 months from any of the following federal means - tested benefit prog rams: Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) ( formerly the Food

### 3

OMB Number: 1845
- 0001 Revised: 10/22/2013 Stamp Program ) , Free or Reduced Price Lunch, Temporary Assistance for Needy Families (TANF), and Special Supplemental Nutrition Program for Women , Infants, and Children (WIC); or 3) The independent student, independent student’s spouse, or the dependent student's parent(s) is a dislocated worker. All assets are excluded from consideration when calculating the EFC for families who meet the SNT require ments resulting in a Simplified Needs Analysis that utilizes the following six components: 1) Adjusted gross income; 2) Federal taxes paid; 3) Untaxed income and benefits; 4) The number of family members; 5) The number of family members (excluding the parents) in posts econdary education; and 6) An allowance (A) for federal and other taxes, as defined in Section 475(c)(2) of the HEA for parents and dependent students and in Section 477(b)(2) of the HEA for independent students with dependents, or (B) for federal and local i ncome taxes, as defined in Section 476(b)(2) of the HEA for independent students without dependents. In addition to the Simplified Needs Analysis, there is another circumstance where the need analysis formula to determine an EFC is modified. Section 479( c) of the HEA further simplifies the application by establishing an Automatic Zero (Auto Zero) formula permitting the automatic determination of an EFC of zero for families within a certain income threshold, and who file or are eligible to file the IRS F or ms 1040A or 1040EZ or who received benefits from one of the federal means - tested benefit programs described above, or for those who meet the dislocated worker criteria. The College Cost Reduction and Access Act of 2007 (P.L. 110 - 84) indexed the income thr eshold to be updated annually according to increases in the Consumer Price Index (CPI). For the 2014 - 2015 application cycle the income threshold will be $ 24 ,000 for the Auto Zero formula. The Auto Zero formula excludes other income and all assets for the purpose of calculating an EFC. Independent students with no dependents other than a spouse are not eligible to receive an automatic zero EFC determination. Once the CPS processes the applicant’s data using the appropriate need analysis formula, the Depa rtment sends an ISIR electronically to the postsecondary institutions the applicant listed on the FAFSA . An ISIR is also sent to the S tate grant agencies (based on the applicant’s state of legal residence), as well as the states where the institutions the applicant listed on his or her FAFSA are located. The Department notifies the applicant by sending a Student Aid Report (SAR) in the language the applicant used to submit the FAFSA. Similar to the ISIR, the SAR will contain the results of the processed application, including the student’s EFC, a transcript of the information that the student originally reported on the FAFSA, and other relevant information (e.g., the applicant’s financial aid history from the Department’s National Student Loan Data System (NSLDS)). There are three versions of the SAR that an applicant may receive; a paper SAR, a paper SAR Acknowledgment, or an eSAR. 1) The paper SAR is a full summary that is mailed to applicants who filed a paper FAFSA and who did not provide an e - mail add ress. A paper SAR is also mailed to applicants whose records were rejected due to critical errors during processing . 2) The SAR Acknowledgment is a condensed paper SAR that is mailed to applicants who applied electronically , but did not provide an e - mail add ress and do not meet the criteria for a full SAR. 3) The eSAR is an online version of the SAR that is available on FOTW to all applicants with a PIN . Notifications for the eSAR are sent to students who applied electronically or by paper and provided an e mail address. These notifications are sent by e - mail and include a secure hyperlink that takes the user to the FOTW site. Applicants are expected to review the information on their SAR and, if necessary, correct errors in the reported information, verify the responses if so requested, and supply any missing information. Specifically, there are several ways that an applicant can correct, update or provide additional information: 1) FOTW – Any applicant who has a Federal Student Aid PIN (FSA PIN) – regardless of how they originally applied – may correct any of the data on the FAFSA, except t he applicant’s Social Security N umber (SSN), by using the corrections functionality on the FOTW sit e.

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OMB Number: 1845
- 0001 Revised: 10/22/2013 2) Paper SAR – Applicants who receive or request a paper SAR can make hand - written corrections or additions directly on the paper SAR and mail it back to the Department. Corrections to the applicant’s SSN can be made using the paper SAR. Note that althou gh the paper SAR can be used to make changes, the SAR Acknowledgment and the eSAR cannot be used for corrections. 3) FAA Access - With the applicant’s permission, an institution can use FAA Access to correct the FAFSA. 4) Electronic Other – With the applicant’s permission, corrections can be made via the postsecondary institution’s third - party servicer, a postsecondary institution’s mainframe computer, or a postsecondary institution’s proprietary software for the student. 5) Federal Student Aid Information Center ( FSAIC) – FSAIC has the ability to assist applicants with a limited amount of changes. Any applicant, who has their Data Release Number (DRN) which is included on the applicant’s SAR , can make changes to the postsecondary institutions listed on their FAFSA or change their address by calling FSAIC. An applicant who corrects and/or updates (as defined in 34 CFR 668.55) their FAFSA resubmits the information to the Department. The Department, in turn, processes the changed information and sends the applicant a revised SAR. For most applicants the application process is now concluded, as the Department has processed the most accurate and complete information for use in the need analysis formula and the postsecondary institution is able to determine eligibility and award aid. Regulations, however, established a verification process (as defined in 34 CFR 668, Subpart E) that require s some applicants to provide documentation to the postsecondary institution to confirm the information reported on the FAFSA. These procedures “...govern[s] the verification by institutions of information submitted by applicants for student financial assistance in connection with the calculation of their expected family contributions (EFC).” Applications are selected for verificatio n either by the CPS or by the postsecondary institution. A postsecondary institution must verify all applications the CPS selects for verification. For students selected for verification, they must complete the verification process with the postsecondary institution, and then the postsecondary institution can award aid once any final changes are submitted to the CPS for processing. In conclusion, the above narrative provides an overview of the application process that exists to determine an applicant’s e ligibility for Title IV, HEA program assistance . Since Title IV, HEA funds should only be awarded to eligible students and the amounts awarded should reflect the actual need of the applicant and family, the awarding of aid by the financial aid office at t he postsecondary institution does not occur until the applicant has completed the entire application process – initial submission, review, corrections and/or verification, if necessary. The entire application process allows the Department to capture the m ost complete and accurate information for use in the need analysis formula and reduces the possibility that an applicant could receive Title IV, HEA funds they are not eligible to receive. **3. Describe whether, and to what extent, the collection of inform ation involves the use of autom**  **ated, electronic, m** **echanical, 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**  **colle ction. Also describe any consideration given to using technology to reduce burden.**  Over time, the Department has made several process improvements that have utilized technology advancements. The following describes some components of the application pro cess that have incorporated such advancements. **FAFSA on the Web (FOTW)**  Section 483(a)(3) of the HEA mandates that, “The Secretary shall produce, distribute, and process forms in electronic format...”. Subsequently, the Department developed FOTW in 1998. FOTW has grown to be the primary entry point for tens of millions of students who apply for F ederal, S tate and institutional financial aid. The Department endeavors to improve FOTW continually to further simplify the application experience for students and families. The following describes the benefits of using FOTW :
 Applications submitted through FOTW are processed much faster than the paper or PDF versions of the FAFSA.  Applicants that have previously applied for aid benefit by completing the Renewal FAFSA, which retains certain static data. Of the static data elements, o nly information that has changed since the previous FAFSA submission needs to be updated and the new data added .  Applicants that need to correct or provide missing information can do so easily by returning to FOTW.

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OMB Number: 1845
- 0001 Revised: 10/22/2013

 FOTW offers skip - logic and assumption - logic that creates a customized, smart application experience based on an applicant’s personal data and previous answers.  Applicants who use FOTW benefit from web edits that ensure all required fields are completed and all data conflicts are resolved prior to application submission, which makes for a reduced application rejection rate duri ng processing. (Ap proximately 13% of paper FAFSAs and 3% of electronic FAFSAs are rejected due to errors or other anomalies. These percenta ges are for non - signature rejects only.)  FOTW is a safe and secure Web site that uses standard commercial encryption protocols that de termine the highest encryption level the browser will support.  In compliance with the Americans with Disabilities Act, FOTW is 508 compliant and accessible to visually impaired applicants. **FSA PIN** The FSA PIN is a 4 - digit number used in combinati on wit h a SSN , name, and date of birth for authentication and identification purposes, and allows access to an individual’s personal information on Department Web sites, such as FOTW. Students and parents can each apply for their own FSA PIN. The FSA PIN can a lso be used as an electronic signature. Since the submission of the FAFSA requires the applicant’s signature and the parent’s signature if the applicant is a dependent student and parental information is provided, the FSA PIN facilitates an easier applica tion experience, eliminating the need for a paper signature submission. In addition, the FSA PIN can be used each year to access the Renewal FAFSA and to access FAFSA data and make corrections or updates. **Custo mer Service**  **– Federal Student Aid Informatio**  **n Center ( FSAIC**  **)** In addition to the assistance provided by FSAIC when handling inquiries about the financial aid process and questions about the application, FSAIC offers technological features that have simplified the application experience for many appli cants.

 Live Help – Customers submitted 1.34 million inquiries to FSAIC in 2012 via web chat. That was 13.7% of all FSAIC interactions that year. Following a usability study of FSAIC’s Live Help capability in 2011, the Department implemented several improvements in 2012 including: o visually differentiated text for customer and customer service agent, o timestamps, o status indicators to show when an agent is typing, o improved chat window layout, and o session expiration to protect customer information.

 Automated Phone Self - Service – Changes to the FSAIC interactive voice response unit (IVRU) menus made in 2012 substantially increased customer awareness of self - service functionality for some of the most common customer inquiries including a FAFSA application status check, National Student Loan Data System loan history, and a seasonally rotated list of frequently asked questions. These features are available to customers 24 hours a day, 7 days a week and require no agent assistance. Customer completion of calls wit hin the IVRU increased from 919k in 2011 to 2.01 million in 2012. **Image and Data Capture (IDC)** The Department has maintai ned the IDC document management system. The system scans images, captures data, and sends the data for processing to the CPS. The I DC utilizes optical character recognition (OCR) to electronically recognize and capture typed or hand - written data from the paper FAFSA, PDF FAFSA and SAR. Use of this technology results in the automation of data entry tasks, thus reducing the processing time for applicants. **4. Describe efforts to identify duplication. Show specifically why any sim ilar information already available**  **cannot be used or m odified for use for the purposes described in Ite**  **m 2 above.**  The FAFSA collection requirements do not contain any duplication of data elements. Because legislation requires that the FAFSA be completed annually by applicants, returning applicants encounter similar questions in subsequent years. To reduce that burden, the Renewal FAFSA is available and reu ses much of the data previously submitted. Required responses on the Renewal FAFSA are limited to income and asset questions likely to change from year to year. The review and corrections segment of the application process does not duplicate the process of initial data collection . Reviewing and correcting the application is also fundamental to the application experience because it

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OMB Number: 1845
- 0001 Revised: 10/22/2013 creates an opportunity to obtain the most accurate applicant information. **5. If the collection of information im pacts smal** **l businesses or other sm all entities, describe any m** **ethods used to m** **ini mize burden. A sm**  **all entity m ay be (1) a sm**  **all business which is dee med to be one that is**  **independently owned and operated and that is not dom inant in its field of operation; (2) a sm**  **al l organization**  **that is any not -**  **for -**  **profit enterprise that is independently owned and operated and is not dom inant in its field;**  **or (3) a sm all governm** **ent jurisdiction, which is a government of a city, county, town, township, school district, or special dis**  **trict with a population of less than 50,000.** The collection of eligibility information for the awarding of student aid does not impact small businesses. **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 the application process was not completed and data elements not collected, the Department would be unable to make an accurate determination of fi nancial need and subsequently award any Title IV, HEA program assistance, as mandated . In addition, the HEA requires annual determination of the applicant’s need for Title IV, HEA program assistance. If the data were collected less frequently, the Depart ment would be in violation of the law. A lthough an applicant must reapply and receive a new need analysis for every year that student aid is requested, use of the Renewal FAFSA, as described previously, reduces the amount of new data that a student must p rovide. As a part of the annual application process, the corrections component provides an opportunity for the applicant to make corrections. The corrections component is crucial in assuring that comprehensive, accurate data is used to calculate the ap plicant’s EFC and overall financial aid eligibility. If the Department were unable to request verification or correction of submitted data, the EFC could be calculated using questionable or erroneous data. In addition, errors discovered as a result of mu ltiple federal database matches (e.g., SSA, Department of Homeland Security (DHS), Veteran Affairs, etc.) could not be corrected. The result would be countless incomplete or inaccurate FAFSA applications and, potentially, millions of incorrect eligibility determinations resulting in the loss of taxpayer dollars by awarding Title IV , HEA program assistance based on erroneous applicant data. **7. Explain any special circumstances that would cause an inform ation collection to be conducted in a m**  **anner:**  **requirin g respondents to report inform**  **ation to the agency m ore often than quarterly;**   **requiring respondents to prepare a written response to a collection of inform ation 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, m edical, governm** **ent contract, grant -**  **in**   ** aid, or tax records for m****ore than three years;**  **in connection with a statistical survey, that is not designed to produce vali d 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 OM**  **B;**  **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 respon dents to submit proprietary trade secrets, or other confidential inform**  **ation unless the agency can dem** **onstrate that it has instituted procedures to protect the inform ation’s**  **confidentiality to the extent permitted by law.** The application does not invoke s pecial circumstances, as described in the Paperwork Reduction Act submission instructions. **8. As**  **applicable, state that the Departm**  **ent has published the 60 and 30 Federal Register notices as required**  **by 5 CFR 1320.8(d), soliciting comments on the inform ation**  **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.**

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OMB Number: 1845
- 0001 Revised: 10/22/2013
**Describe effort s 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 form**  **at (if any), and on the data elem ents to be recorded, discl**  **osed, or reported. Consultation with representatives of those from** **whom inform**  **ation is to be obtained or those who m ust**  **com pile records should occur at least once every 3 years** 

**– even if the collection of inform**  **ation activity is the sam** **e as in prior perio ds. There may be circumstances that m**  **ay preclude consultation in a specific situation. These circumstances should be explained.**  The Department publishe d the 60
- day Federal Register notice inviting public comment on May 6, 2013, ( 78 FR 26334, 26334
- 26336 ) . During the 60 days, w e receive d 9 3 comments from individuals or organizations and address ed the ir comments in a separate document entitled FSA Application Comments Tracking Summary. T he Department also consult s with an advisory board of f inancial a id professionals and federal student aid applicants on a yearly basis. Financial a id professionals provide feedback on planned changes to the application and application process. Students and parents participate in usability studies on existing functions of the application and/ or proposed enhancements. A satisfaction survey is also available to users as they exit FOTW. The quantitative and qualitative data gathered is monitored and reported on a quarterly basis. C onsideration of the views expressed by these groups is part of the annual development process of the application. The survey is approved und er OMB control number 1845 - 00 01. T he n ame s and affiliations of the FAFSA advisory team will be provided to OM B upon request. **9. Explain any decision to provide any paym**  **ent or gift to respondents, other than remuneration of contractors or grantees**  **with m eaningful justification**  **.** There are no payments or gifts for the completion and/or submission of the application. **10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable inform**  **ation (PII) is being collected, a Privacy Act statem**  **ent 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 statem**  **ent 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 statem** **ent is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state that the Departm**  **ent make s**  **no pledge about the confidentially of the data.**  The confidentiality of the data collected is discussed in the Routine Uses section of the System of Records Notice for the Federal Student Aid Application File (18 - 11 - 01), published in 64 FR 30159 – 30161 (June 4 , 1999), as corrected by, 64 FR 72407 (December 27, 1999), as corrected by, 65 FR 11294 (March 2, 2000), as corrected by 66 FR 18758 (April 11, 2001), and as corrected by, 74 FR 68802
- 68808 (December 29, 2009). A section on privacy, printed on page 10 of the paper FAFSA and linked from the homepage of FOTW, informs the student that postsecondary educational institutions and State financial aid agencies to which the student requests his or her data be sent will have access to the data, and that the grant ag encies in the applicant’s state of legal residence will receive certain information even if the student does not provide consent pursuant to section 483(a) of the HEA. Privacy Act information is repeated on the paper SAR and accessible at all times from F OTW. In addition, agencies such as law enforcement agencies, the Office of Management and Budget (OMB), the Department of Justice (DOJ), the Government Accountability Office (GAO), Congress, and other entities have access to the data. Consistent with a n otice of an altered system of records that was published in the Federal Register on April 19, 2010 (75 FR 20346), the Department has authorized a small number of secondary schools and local education agencies (LEAs) to 2 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
- 0001 Revised: 10/22/2013
obtain information about their studen t’s FAFSA Completion data as a part of a program to facilitate students’ completion of the FAFSA. No other individuals have access to this information without the express written consent of the applicant or as authorized by the Secretary consistent with t he provisions of Section 483(a)(3)(E) . **11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other m**  **atters that are commonly considered private. The justification should**  **include the reasons why the agency considers the questions necessary, the specific uses to be m ade of the**  **inform ation, the explanation to be given to persons from** **whom the inform**  **ation is requested, and any steps to be taken to obtain their consent.**  Except for question 23 (have you been convicted for the possession or sale of illegal drugs for an offense that occurred while you were receiving federal student aid) and questions 24 and 25 (what is your parents’ level of education), the FAFSA does not c ontain questions of a sensitive nature beyond those needed to obtain the information necessary to complete the need analysis and calculate an EFC. Question 23 is used to determine a student’s eligibility for Title IV assistance in accordance with sectio n 484(r) of the HEA. Questions 24 and 25 are often used to determine whether an applicant is a first - generation college student and may be used by S tate grant agencies, scholarship programs, institutions, and the TRIO programs, which often give special co nsideration to first - generation college students. The FAFSA instructions inform applicants that their response to question 23 may affect their eligibility for F ederal student aid. Other FAFSA instructions inform applicants that their response to questi ons 24 and 25 do not affect their eligibility for F ederal student aid. **12. Provide estim**  **ates of the hour burden of the collection of inform ation. The statement should:**   **Indicate the number of respondents by affected public type (federal governm ent,**  **individuals or households, private sector** 

**– businesses or other for**  **- profit, private sector** 

**– not** **- for**  **- profit**  **institutions, farms, state, local or tribal governm ents), frequency of response, annual hour**  **burden, and an explanation of how the burden was estima ted, 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 inform**  **ation on which to base hou r burden estimates. Consultation with a sam** **ple (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 com plexity, show the range of estim**  **ated hour b**  **urden, and explain the reasons for the variance. Generally, estim ates should not include**  **burden hours for custom ary and usual business practices.**   **If this request for approval covers m ore than one form** **, provide separate hour burden estim ates**  **for each form and aggregate the hour burdens in the**  **ROCIS IC Burden Analysis Table.**  **(The table should at**  **mini mum**  **include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)**   **Provide estim ates of annualized cost to respondents of the**  **hour burdens for collections of inform**  **ation, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for inform**  **ation collection activities should not be included here. Instead, this cost should be in**  **cluded in Item 14.** The estimates included are the result of the Department’s efforts to determine the public’s burden as it relates to the application process for F ederal student aid. The Applicant Burden Model (ABM), measures applicant burden through an assessment of the activities each applicant conducts in conjunction with other applicant characteristics and in terms of burden, the average applicant’s experience. Key determinants of the ABM include:

 The total number of applicants that will potentiall y apply for federal student aid;  How the applicant chooses t o complete and submit the FAFSA ( e.g., by paper or electronically via FOTW ) ;  How the applicant chooses to submit any corrections and/or updates (e.g., the paper SAR or electronically via FOTW Corr ections);  The type of SAR document the applicant receives ( eSAR, SAR acknowledgment, or paper SAR );  The formula applied to determine the applicant’s EFC (full need analysis formula, Simplified Needs Test or Automatic Zero); and

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OMB Number: 1845
- 0001 Revised: 10/22/2013

 The average amount of time involved in preparing to complete the application. The ABM is largely driven by the number of potential applicants for the application cycle. The total application projection for 2014 - 2015 is based upon two factors - estimates of the total enrollment in all degree - granting institutions and the percentage change in FAFSA sub missions for the last completed or almost completed application cycle . The ABM is also based on the application option s available to students and parents. The Department accounts for each application component based on W eb trending tools, survey information, and other Department data sources. The 2014 - 2015 application projections are estimated based on one response per FAFSA submitted. The projections account for two factors, which include college enrollment projections and FAFSA submission rates for the previously completed cycle. The Projections of Education Statistics prepared by the U.S. Department of Education, N ational Center for Education Statistics (NCES), Integrated Postsecondary Education Data System provides estimates of the total enrollment in all degree - granting institutions, as shown in Table 1. **Table 1.** Enrollment projections for 2014 from NCES Project ion s of Education Statistics to 2020 [in thousands] **Year Enrollment Projections**  2011 21,294 2012 21,556 2013 21,792 2014 22,042 2015 22,252 2016 22,509 2017 22,842 2018 23,219 2019 23,569 2020 23,867 For 2014 - 2015, we estimate total applicant volume by using the values reflected in Table #1 for total college enrollment projection to calculate the high alternative projection. The high alternative projection is used to account for the difference in the number of students who may apply for aid an d the number of students who may actually enroll in college. After a review of prior year projections, the Department will utilize a fixed 15 percent in conjunction with the percentage change in FAFSA submissions of the last completed application cycle. There was no percentage change in FAFSA submissions for this prior cycle. Based on these factors, the Department estimates that 25,348,645 total applicants will submit a FAFSA for 2014 - 2015; an increase of 294,836 applicants from the 2013
- 2014 estimates. Once the applicant volume is projected, we determine the total estimated burden and cost by examining each FAFSA completion method. The completion method reflects how applicants choose to complete and submit the FAFSA, and indicates the needs analysis fo rmula the applicant was presented with when they completed the FAFSA. Each completion method is assigned an individual burden estimate to reflect the average time an applicant will spend to prepare, complete and submit a FAFSA and/or correction. For 2014
- 2015 estimates, we determined that the 2012 - 2013 cycle offers a more complete data set to help baseline projections for individual burden. It should also be noted that the Department determined that recordkeeping would not be documented as a component of the burden estimate. Since the Department retains, for the applicant, summaries of the data submitted and a history of their changes, the need for an applicant to retain a set of records is optional. The components that were included in the individual b urden est imate include information from W eb trending tools and user perception data from surveys and this allowed us to estimate the individual burden for each completion method. The individual burden estimate includes the following: 1) Preparation – Average time it takes to review instructions and gather the documents necessary to complete the FAFSA (e.g., paper FAFSA, copies of W - 2 Forms, Student/Spouse and/or Parent’s Federal Income Tax Returns, bank statements);

### 10

OMB Number: 1845
- 0001 Revised: 10/22/2013 2) Completion – Average time it takes for data entry (paper or electronic), referencing instructions, or accessing on - line help or calling customer service; 3) Submission – Average time it takes to review the Certification Statement, apply signatures, make copies of paper forms or p rint electronic outputs, and if necessary, obtain postage and mail. As a result, Table 2 details the initial submission behavior (completion method) and provides the total burden for submission of the FAFSA; along with associated costs by type of applicat ion. Table 3 details the corrections behavior by type of corrections submitted and allows us to calculate the burden associated with each correction method; associated costs by type of correction are also provided . Table 4 shows the total number of SARs distributed as a result of the initial submission of the FAFSA and any corrections made. This table also identifies the type of SARs distributed and provides associated cost for each . Lastly, Table 5 summarizes the overall total burden and overall total costs for the 2014 - 2015 Federal Student Aid Application. The total estimated burden for the 2014 - 2015 Federal Student Aid Application is **26,164,366 hours**  . Table 5 also summarizes the annual cost burden to complete the application process, which is **$153,6 25.28**  , a decrease from the previous year of $36,599.48 . The reason why the estimated total cost is expected to decrease is because the number of applicants to submit a paper FAFSA or a paper SAR is expected to decrease as applicants become more W eb oriented. This cost is attributed to the individual postage cost of 46 cents that would be required of applicants who choose to submit a paper FAFSA (Table 2) or a paper SAR (Table 3). **Table 2.** Initial Submission of FAFSA
**Type of Application Filed Type**  **of FAFSA Applicant**  **(Independent or Dependent)**  **Percent Estimated**  **Number of Applicants**  **(Volume) Estimated** 

**Individual Applicant**  **Burden (Hours)**  **Estimated**

**Individual Applicant Cost**  **(Dollars) Total** 

**Burden for All**  **Applicants (Hours)**  **Total Cost for**

**All Applica nts**  **(Dollars) FAFSA on the Web (FOTW)**  **FOTW** (IC 1) Overall Usage 42.35% The online version of the FAFSA that offers applicants a customized experience. Dependent 43% 4,616,115 1.22 $
- 5,631,660 $
- Independent 57% 6,119,036 0.71 $
- 4,344,516 $
- **Subtotals 10,735,151**  **9,976,176** $
- **FOTW -**  **Renewal** (IC 2) Overall Usage 44.65% The online version within FOTW for applicants who have previously completed the FAFSA. Dependent 44% 4,979,995 0.90 $
- 4,481,995 $
- Independent 56% 6,338,175 0.56 $
- 3,549,378 $
- **Subtotals 11,318,170**  **8,031,373** $
- **FOTW -**  **EZ** (IC 3) Overall Usage 5.60% The online version within FOTW for applicants who qualify for the Simplified Needs Test (SNT) or Automatic Zero (Auto Zero) needs analysis formulas. Dependent 33% 468,443 1.12 $
- 524,656 $
- Independent 67% 951,081 0.68 $
- 646,735 $
- **Subtotals 1,419,524**  **1,171,391** $
- **FOTW -**  **EZ Renewal** (IC 4) Overall Usage 5.70% The online version within FOTW for applicants who have previously completed the FAFSA and who qualify for the Simplified Needs Test (SNT) or Automatic Zero (Auto Zero) needs analysis formulas. Dependent 34% 491,257 0.83 $
- 407,743 $
- Independent 66% 953,616 0.52 $
- 495,880 $
- **Subtotals 1,444,873**  **903,623** $
-

**FOTP -**  **FAFSA on the Phone** (IC 5) Overall Usage 0.0175% FSAIC customer service representatives assist applicants by filing the Dependent 27% 1,198 1.03 $
- 1,234 $
- Independent 73% 3,238 0.63 $
- 2,040 $
-

### 11

OMB Number: 1845
- 0001 Revised: 10/22/2013

**Type of Application Filed Type**  **of FAFSA Applicant**  **(Independent or Dependent)**  **Percent Estimated**  **Number of Applicants**  **(Volume) Estimated** 

**Individual Applicant**  **Burden (Hours)**  **Estimated**

**Individual Applicant Cost**  **(Dollars) Total** 

**Burden for All**  **Applicants (Hours)**  **Total Cost for**

**All Applica nts**  **(Dollars)** FAFSA on their behalf through FOTW. **Subtotals 4,436**  **3,274** $
- **FOTW -**  **FAFSA on the Phone EZ**  (IC 6) Overall Usage 0.0025%
FSAIC customer service representatives assist applicants by filing the FAFSA on their behalf through FOTW Dependent 28% 178 0.94 $
- 167 $
- Independent 72% 456 0.60 $
- 274 $
- **Subtotals 634**  **441** $
- **School Entry FAA Access**  (IC 7) Overall Usage 0.25% With the FAFSA filer’s permission, an institution can use FAA Access to submit the FAFSA Dependent 25% 15,843 1.47 $
- 23,289 $
- Independent 75% 47,529 0.96 $
- 45,628 $
- **Subtotals 63,372**  **68,917** $
- **FAA Access -**  **Renewal** (IC 8) Overall Usage 0.20% With the FAFSA filer’s permission, an institution can use FAA Access to submit the Renewal FAFSA for an applicant Dependent 28% 14,195 1.15 $
- 16,324 $
- Independent 72% 36,502 0.81 $
- 29,567 $
- **Subtotals 50,697**  **45,891** $
- **FAA Access -**  **EZ** (IC 9) Overall Usage 0.20% With the FAFSA filer’s permission, an institution can use FAA Access to submit the Renewal FAFSA for an applicant Dependent 41% 20,786 1.37 $
- 28,477 $
- Independent 59% 29,911 0.93 $
- 27,817 $
- **Subtotals 50,697**  **56,294** $
- **FAA Access -**  **EZ Renewal** (IC 10) Overall Usage 0.20% With the FAFSA filer’s permission, an institution can use FAA Access to submit the Renewal FAFSA for an applicant Dependent 43% 21,800 1.08 $
- 23,544 $
- Independent 57% 28,897 0.77 $
- 22,251 $
- **Subtotals 50,697**  **45,795** $
- **Electronic Other** (IC 11) Overall Usage 0.60% "Electronic Other Original" refers to the submission of FAFSA data using the Electronic Data Exchange (EDE) process. With the FAFSA filer’s permission, a FAFSA can be submitted via: a school’s third party servicer, a school’s mainframe computer, or a schoo l’s proprietary software. Dependent 22% 33,460 1.25 $
- 41,825 $
- Independent 78% 118,632 0.87 $
- 102,913 $
- **Subtotals 152,092**  **144,738** $
-

**Paper Submissions**  **PDF FAFSA or Paper FAFSA** (IC 12) Overall Usage 0.23% The paper version of the FAFSA printed by the Department and provided Dependent 38% 22,155 2.09 $ 0.46 46,303 $ 10,191.30 Independent 62% 36,147 1.71 $ 0.46 61,812 $ 16,627.62

### 12

OMB Number: 1845
- 0001 Revised: 10/22/2013

**Type of Application Filed Type**  **of FAFSA Applicant**  **(Independent or Dependent)**  **Percent Estimated**  **Number of Applicants**  **(Volume) Estimated** 

**Individual Applicant**  **Burden (Hours)**  **Estimated**

**Individual Applicant Cost**  **(Dollars) Total** 

**Burden for All**  **Applicants (Hours)**  **Total Cost for**

**All Applica nts**  **(Dollars)** for applicants who are unable to access the Internet or the online version of the printed FAFSA for applicants who can access the Internet but are unable to complete the form using FOTW. **Subtotals 58,302**  **108,115** $ 26,818.92

**Total Applicants (Responses)**  **25,348,645 Applicant Burden (Hours)**  **20,556,028 Applicant Cost (Dollars)**  **$26,818.92 Table 3.**  Correcting Submitted FAFSA Information

**Type of Correction Type of**  **FAFSA Respondent**  **by Filing Option**  **(Independent or**  **Dependent) Percent**  **Estimated Number of**  **Corrections Received**  **(Volume) Estimated** 

**Individual Burden**  **(Hours) Estimated** 

**Individual Applicant Cost**  **(Dollars) Total Burden** 

**for All Respondents**  **(Hours) Total Cost for** 

**All Applicants**  **(Dollars)**

**FOTW -**  **Corrections** (IC 13) Overall Usage 57.00% Any applicant who has a Federal Student Aid PIN (FSA PIN) – regardless of how they originally applied – may correct using Corrections with FOTW. Dependent 54% 6,788,012 0.16 $
- 1,086,082 $
- Independent 46% 5,782,381 0.11 $
- 636,062 $
-
**Electronic Other -**  **Corrections** (IC 14) Overall Usage 19.00% With the applicant's permission, corrections can be made via: a school’s third party servicer, a school’s mainframe computer, FAA Access or a school’s proprietary software. Dependents & Independents 4,190,131 0.16 $
- 670,421 $
-

**Paper SAR**  (IC 15) Overall Usage 1.25% Applicants can write corrections directly on the paper SAR and mail for processing. Dependents & Independents 275,666 0.32 $ 0.46 88,213 $ 126,806.36
**FAA Access** - Corrections (IC 16) Overall Usage 8.00% With the FAFSA filer’s permission, an institution can use FAA Access to correct the FAFSA. Dependents & Independents 1,764,266 0.16 $
- 282,283 $
-
**Internal Department Corrections**  (IC 17) Overall Usage 14.00% The Department will submit an applicant's record for system
generated corrections. There is no burden to the applicants under this correction type. Dependents & Independents 3,087,465 0.00 $
- 0 $
-

**FSAIC Corrections** (IC 18) Overall Usage 0.75%

### 13

OMB Number: 1845
- 0001 Revised: 10/22/2013

**Type of Correction Type of**  **FAFSA Respondent**  **by Filing Option**  **(Independent or**  **Dependent) Percent**  **Estimated Number of**  **Corrections Received**  **(Volume) Estimated** 

**Individual Burden**  **(Hours) Estimated** 

**Individual Applicant Cost**  **(Dollars) Total Burden** 

**for All Respondents**  **(Hours) Total Cost for** 

**All Applicants**  **(Dollars)**
Any applicant, who has their Data Release Number (DRN), can make changes to the postsecondary institutions listed on their FAFSA or change their address by calling FSAIC. Dependents & Independents 165,400 0.05 $
- 8,270 $
-

**Total Corrections (Responses) 22,053,321**  **Applicant Burden (Hours) 2,771,330**  **Applicant Cost (Dollars) $126,806.36**  **Table 4.** Reviewing FAFSA Information – Student Aid Report Distribution

**Type of SAR Sent Type of FAFSA**  **Respondent by Filing Option**  **(Independent or Dependent)**  **Documents**

**Sent (Volume)**  **Estimated**

**Individual Burden**  **(Hours) Estimated** 

**Individual Applicant**  **Cost (Dollars)**  **Total Burden**

**for All Applicants**  **(Hours) Total Cost** 

**for All Applicants**  **(Dollars) SAR Electronic (eSAR)**  (IC 19) Distribution 93.5% PDF version of the SAR for applicants who applied electronically or by paper and provided an e - mail address. Dependents & Independents 44,320,838 0.05 $
- 2,216,042 $
-
**SAR Acknowledgment** (IC 20) Distribution 3.5% Condensed paper SAR that is mailed to applicants who applied electronically but did not provide an e - mail address. Dependents & Independents 1,659,069 0.10 $
- 165,907 $
-
**Paper SAR** (IC 15) Distribution 3% Full paper summary that is mailed to applicants who filed a paper FAFSA and who did not provide an e - mail address and to applicants whose records were rejected due to critical errors during processing. Dependents & Independents 1,422,059 0.32 $
- 455,059 $
-

**Total SARs Distributed 47,401,966**  **Applicant Burden (Hours)**  **2,837,008 Applicant Cost (Dollars)**  **$0.00**

### 14

OMB Number: 1845
- 0001 Revised: 10/22/2013
**Table 5.** Total Burden and Total Costs for 2014 - 2015 F ederal Student Aid Application **Application Process Responses**  **Burden (Hours) Cost (Dollars)**  Initial Submission **25,348,645 20,556,028**  **$26,818.92** Corrections **22,053,321 2,771,330**  **$126,806.36** SAR Review 0 **2,837,008** $0.00 **Total Annual Responses 47,401,966**  **Total Burden for All Applicants 26,164,366**  **Total Cost for All Applicants $ 153,625.28**  **13. Provide an**  **estim ate of the total annual cost burden to respondents or record keepers resulting from** **the collection of inform**  **ation. (Do not include the cost of any hour burden shown in Items 12 and 14.)**  **The cost estimate should be split into two com ponents: (a) a tot**  **al capital and start -**  **up cost com ponent**  **(annualized over its expected useful life); and (b) a total operation and m aintenance and purchase of**  **services component. The estim ates should take into account costs associated with generating,**  **maintaining, and disc losing or providing the inform**  **ation. Include descriptions of methods used to estim**  **ate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the tim**  **e period over which costs wil l be incurred.**  **Capital and start -**  **up costs include, am ong other item**  **s, preparations for collecting inform ation such**  **as purchasing computers and software; m onitoring, sampling, drilling and testing equipment; and**  **acquiring and maintaining record storage fac ilities.**   **If cost estim ates are expected to vary widely, agencies should present ranges of cost burdens and**  **explain the reasons for the variance. The cost of contracting out inform ation collection services**  **should be a part of this cost burden estimate. In developing cost burden estim**  **ates, agencies may consult with a sam** **ple of respondents (fewer than 10), utilize the 60 -**  **day pre -**  **OMB submission public comm** **ent process and use existing economic or regulatory im pact analysis associated with the**  **rulemaking contai ning the inform**  **ation 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 inform**  **ation collection, (3) for reasons other than to provide information or keep records for the**  **governm ent**  **or (4) as part of custom ary and usual business or private practices.**  **Also, these estimates should not include the hourly costs (i.e., the m** **one tization of the hours) captured**  **above in Item 12**  **Total Annualized Capital/Startup Cost :**  **Total Annual Costs (O&M) :** 

**____________________ Total Annualized Costs Requested**  **:** There are no other annual burden costs to respondents or record keepers other than what is shown in #12. **14. Provide estim**  **ates of annualized cost to the Federal governm ent. 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 inform**  **ation. Agencies also may aggregate cost estim ates fr**  **om Ite**  **ms 12, 13, and 14 in a single table.**  The projected cost to the federal government to produce, process, and distribute the application and related application products or materials is **$83,589,846 .**  The projections include the costs associated with the Department’s CPS and other costs like printing, mailing and customer service. See the following Table for cost details.

### 15

OMB Number: 1845
- 0001 Revised: 10/22/2013
**Table 6.** Annual Costs **Projected Costs Category 1**  **– Front End Business Integration (FEBI) per Applicant Services:**  This cate gory is the primary delivery area performed under the FEBI contract under the tiered per applicant pricing structure. It consists of system development and maintenance of the FEBI Information Technology (IT) products and the primary operational programs: C entral Processing Systems (CPS) mainframe software and systems, develop the paper application and other paper products related to eligibility, status reports, ongoing support of existing software and hardware, management of volume peaks, cooperation with m ultiple contractors, Personal Identification Number (PIN) database, Managing Printing of CPS mailing, Federal Student Aid Information Center (FSAIC), Editorial Services, CPS/ Student Aid Information Gateway (SAIG) Help desk & Customer Communications, Image and Data Capture (IDC), E - mail, Print, and other Operational Services including Conference Support, Participation Management (PM) Operations, Form Support (FAFSA Forms and PM Enrollment Forms,) and Federal Student Aid Training. **$77,870,346**

**Category 2 -**  **Other FEBI Programs and Products: COD Ancillary Services**  Printing, mailing, imaging, and storing paper promissory notes. **$2,664,236 School Products**  Providing schools with the EDExpress suite of software products to participate in Electronic Data Exchange . **$546,950 Postage**  Mailing SARs and SAR Acknowledgments, PIN mailers and PIN reject letters, Renewal Application reminder letters and follow - up letters, subsequent application letters a nd IRS income follow - up notification letters. **$2,508,314**
**Total Projected Annual Cost $83,589,846**  **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 t**  **he size of the reporting universe). Program changes result from** **a deliberate action that m**  **aterially changes a collection of inform ation 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., adjustm**  **ent, program change due to new statute, and/or program** **change due to agency discretion), type of collection (new, revision, extension, reinstatem** **ent with ch ange, reinstatement without change) and include**  **totals for changes in burden hours**  **, responses**  **and cost s**  **(if applicable) .**  The Department is reporting a net burden increase of **204,513** hours attributed to the increase in applicants. We project that the 2014 - 2015 enhancements to the application will not substantively impact burden. Table 7 shows the net burden change and total cost for applicants. The change in total annual responses is also listed in the Table. Total annual response s includ e the original FAFSA submission and corrections. **Table 7**  **.** Net Burden Change **2013 -**  **2014 2014**  **- 2015**  **Change % Change**  **Burden Disposition**

Accounting for change in applicant burden **and** change in applicants. Total Applicants 25,053,809 25,348,645 +294,836 1.18%

. Total Applicant Burden 25,959,853 26,164,366 +204,513 .79%
Total Annual Responses 46,099,00 8 47,401,966 +1,302,958 2.83% Cost for All Applicants $190,224.76 $153,625.28
- $36,599.48
- 19. 24 %

### 16

OMB Number: 1845
- 0001 Revised: 10/22/2013 Updated completion times were calcula ted for each component and have been used t o estimate the burden in Table 8 , excluding the change in the applicant volume. The results demonstrate that the burden for all applicants will remain constant . **Table 8 .**  Applicant Burden Change using 2013 - 2014 Burden Estimates **2013 -**  **2014 2014**  **- 2015** * **Change % Change**  **Burden Disposition**

*Accounting only for change in applicant burden; **does not include** change in applicants. Total Applicants 25,053,809 25,053,809 0 0.00% Total Applicant Burden 25,959,853 25,839,174 - 120,679

- 0.46%
Table 9 shows the increase in burden given the increase in applicants projected for 2014 - 2015. The 1.18 percent increase in applicants would resul t in an increase in burden of 325,912 hours. **Table 9**  **.** Applicant Burden Change and Applicant increase **2013 -**  **2014 2014**  **- 2015** 

*Accounting for increase of applicants and burden change. Total Applicants 25,053,809 25,348,645 +294,836 1.18% Burden Change Estimates - 120,679 +204,513 +325, 192

- 0.46% Adjustment. **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 tim e schedule for the**  **entire project, including beginning and ending dates of the collection of inform**  **ation, com pletion of report,**  **publication dates, and other actions.** The results of the collected information will not be published for tabulation or publication. **17. If seeking approval to not display**  **the expiration date for OMB approval of the inform ation collection,**  **explain the reasons that display would be inappropriate.** The expiration date for OMB approval will not be included on the 2014 - 2015 paper or PDF FAFSA for design reasons, although the OMB control number is displayed. The term of approval and use of the form is apparent in the first - page instructions that inform applicants to send in the form from January 1, 2014 through June 30, 2015 . The expiration date for OMB approval will not be included on the 2014 - 2015 paper SAR for design reasons, although the OMB control number is displayed. The term of approval is apparent in the paper and electronic versions of the application which would have to be submitted in order to generate a SAR . **18. Explain each exception to the certification statem** **ent identified in the Certification of Paperwork Reduction Act.**  Exceptions to the certification requirement are not requested for this information col lection.