1

SUPPORTING STATEMENT

RIN 1840-AD11

Justification

1. Explain the circumstances that make the collection of information necessary. Identify 

any legal or administrative requirements that necessitate the collection. Attach a copy of the 

appropriate section of each statute and regulation mandating or authorizing the collection of 

information.

On July 6, 2012, the President signed Moving Ahead for Progress in the 21st Century Act (MAP21) into law. MAP-21 included two changes to the William D. Ford Federal Direct Loan (Direct 

Loan) Program. Specifically, MAP-21 amended section 455 of the Higher Education Act of 1954, 

as amended (HEA) to extend the 3.4 percent fixed interest rate that applies to Direct Subsidized 

Loans made to undergraduate students to loans for which the first disbursement is made 

before July 1, 2013. Second, the law placed a limit on Direct Subsidized Loan eligibility for new 

borrowers on or after July 1, 2013. Specifically, a new borrower on or after July 1, 2013 is no 

longer eligible to receive additional Direct Subsidized Loans if the period during which the 

borrower has received such loans exceeds 150 percent of the published length of the 

borrower’s educational program. Additionally, the borrower becomes responsible for accruing 

interest on any Direct Subsidized Loan made to the borrower on or after July 1, 2013 if he or 

she is enrolled after reaching this 150 percent limit.

The Department published interim final regulation implementing the changes to the Direct 

Loan Program made by MAP-21. These regulations contained information collection 

requirements of borrowers and institutions, which were previously approved on an emergency 

basis, and for which approval is now sought on a regular basis. No changes have been made to 

the collection since it was approved on an emergency basis.

2. Indicate how, by whom, and for what purpose the information is to be used. Except 

for a new collection, indicate the actual use the agency has made of the information received 

from the current collection.

The Department will use the additional information reported to the COD System to determine 

whether the borrower has remaining eligibility for Direct Subsidized Loans under the new 

regulations at §685.200(f). Similarly, the Department will use the additional information 

reported to NSLDS to determine whether the borrower will become responsible for accruing 

interest on previously received Direct Subsidized Loans.

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

using technology to reduce burden.

All information being collected as part of this collection is only submitted by institutions 

electronically, and in a highly automated format.

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.

Though institutions will be required to report similar information to different systems as a 

result of this collection, the information, itself, is not duplicative. The information that will be 

reported to the COD System will be true as of the time the Direct Loan is disbursed. The 

information that will be reported to NSLDS will be true as of the time that the institution 

reports on the student’s enrollment.

This information is not available from other sources.

5. If the collection of information impacts small businesses or other small entities (Item 8b of 

IC Data Part 2), describe any methods used to minimize burden.

No small businesses are impacted by this collection.

6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to 

reducing burden.

If the information was not collected or was not collected on an as-frequent basis, the 

Department would be unable to administer the Direct Loan Program in a manner that complies 

with the new statutory provisions created by MAP-21.

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

with other agencies for compatible confidential use; or

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

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

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

Special Circumstances Governing Data Collection

This requirement is consistent with the guidelines in 5 CFR 1302.5(d)(2).

8. If applicable, provide a copy and identify the date and page number of publication in the 

Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on 

the information collection prior to submission to OMB. Summarize public comments received 

in response to that notice and describe actions taken by the agency in response to these

comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, 

or reported.

Consultation with representatives of those from whom information is to be obtained or those 

who must compile records should occur at least once every 3 years – even if the collection of 

information activity is the same as in prior periods. There may be circumstances that may 

preclude consultation in a specific situation. These circumstances should be explained.

The collection was initially cleared through emergency procedures outlined in 5 CFR 1320.13, 

the public had no prior opportunity to comment on the collection. However, the Department 

has since provided the public an opportunity to comment on the collection requirements 

through the routine 60-day comment period. During that comment period, the Department 

received no comments on the collection and is not proposing to make any further changes to 

the collection. The public will now have a further 30 days to comment on the collection.

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

remuneration of contractors or grantees.

Payments or Gifts to Respondents

No payments or gifts will be provided to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. 

These requirements do not cover any confidential information.
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11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered 

private. The justification should include the reasons why the agency considers the questions 

necessary, the specific uses to be made of the information, the explanation to be given to 

persons from whom the information is requested, and any steps to be taken to obtain their 

consent.

The Department is not requesting any sensitive data.

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

should:

 Indicate the number of respondents, frequency of response, annual hour burden, 

and an explanation of how the burden was estimated. Unless directed to do so, 

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

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

potential respondents is desirable. If the hour burden on respondents is expected 

to vary widely because of differences in activity, size, or complexity, show the 

range of estimated hour burden, and explain the reasons for the variance. 

Generally, estimates should not include burden hours for customary and usual 

business practices.

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

burden estimates for each form and aggregate the hour burdens in item 16 of IC 

Data Part 1.

 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.

Annual Hour Burden for Respondents/Recordkeepers

Section 685.301(e)--COD Reporting Requirements by Institutions

Section 685.301(e) provides that institutions originating and disbursing loans under the Direct 

Loan Program must report a student’s “payment data” to the Secretary. The term “payment 

data” is defined in 34 CFR 685.102(b) to mean “an electronic record that is provided to the 

Secretary by an institution showing student disbursement information”. The Department has 

implemented this provision by requiring that institutions electronically report student and 

Direct Loan information to the COD System. The new regulation in §685.200(f) provides that a 

borrower is not eligible to receive an additional Direct Subsidized Loan if the sum of the 

borrower’s subsidized usage periods equals or exceeds the borrower’s maximum eligibility 

period. The new regulation also provides different rules for borrowers who are enrolled in 

teacher certification programs for which the institution awards no academic credential, 
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preparatory coursework necessary for enrollment in an undergraduate program, and 

preparatory coursework necessary for enrollment in a graduate or professional program.

The Department will determine whether the borrower has continued eligibility for Direct 

Subsidized Loans. To ensure that the Department has the information necessary to make that 

determination, institutions will be required to report additional information to the 

Department’s COD System. For example, institutions will be required to report: the program’s 

Classification of Instructional Programs (CIP) Code; the credential level of each program; the 

length of the program for which the loan is intended; the enrollment status of the borrower at 

the time the loan is disbursed; whether a loan is for a teacher certification program for which 

the institution awards no academic credential; whether a loan is for preparatory coursework 

necessary for enrollment in an undergraduate program; and whether the loan is for 

preparatory coursework necessary for enrollment in a graduate or professional program.

These data will allow the Department to calculate the borrower’s maximum eligibility period, 

subsidized usage period, and remaining eligibility period as described in §685.200(f)(1)(ii)-

(f)(1)(iv), determine whether the borrower is eligible to receive an additional Direct Subsidized 

Loan, and ensure that borrowers do not receive Direct Subsidized Loans if they are no longer 

eligible to receive a Direct Subsidized Loan under §685.200(f)(2). 

To estimate the total increase in burden imposed on institutions of higher education, the 

Department estimated the average number of reports that each institution submitted to COD 

each business day (by institutional type, i.e., public, private, proprietary). We based our 

calculations of estimated burdens on a 248 business-day year (365 days, less 104 weekend days 

and 13 Federal holidays) and that institutions submit data in large batches, not separately, for 

each individual borrower. We estimate that the additional reporting will add 1 minute (0.02 

hours) of additional burden per report. 

Of the 5,847 institutions that disbursed Direct Loans during the most recently completed award 

year, 1,933 of them are public institutions. The average number of reports per day that public 

institutions submit is 2.73. We further estimate that additional reporting will add 26,174 hours 

(1,933 institutions multiplied by 248 business days, multiplied by 2.73 reports per day, 

multiplied by 0.02 hours per report).

Of the 5,847 institutions that disbursed Direct Loans during the most recently completed award 

year, 1,750 of them are private, not-for-profit institutions. The average number of reports per 

day that private, not-for-profit institutions submit is 1.29. We estimate that additional 

reporting will add 11,197 hours (1,750 institutions multiplied by 248 business days, multiplied 

by 1.29 reports per day, multiplied by 0.02 hours per report).

Of the 5,847 institutions that disbursed Direct Loans during the most recently completed award 

year, 2,164 of them are proprietary institutions. The average number of reports per day that 

proprietary institutions submit is 0.84. We further estimate that additional reporting will add 

9,016 hours (2,164 institutions multiplied by 248 business days, multiplied by 0.84 reports per 

day, multiplied by 0.02 hours per report).
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Collectively, as a result of the new reporting requirements created for public, private and 

proprietary institutions, the total burden associated with §685.301(e), under 1845-NEW1, will 

increase by 46,387 hours (26,174 hours for public institutions + 11,197 hours for private, notfor-profit institutions + 9,016 hours for proprietary institutions).

3. 34 CFR 685.301(e) - additional reporting to the COD 

System

 Individuals

 Private Sector

 Business or other for-profits

Proprietary institutions - additional reporting to the 

COD System 34 CFR 685.301(e) 2,164 450,804 0.02 9,016

 Not-for profits

Not-for-profit institutions - additional reporting to the 

COD System 34 CFR 685.301(e) 1,750 559,860 0.02 11,197

 State, Local, or Tribal Governments

Public institutions - additional reporting to the COD 

System 34 CFR 685.301(e) 1,933 1,308,718 0.02 26,174

TOTAL 34 CFR 685.301(e) - additional reporting to the 

COD System 5,847 2,319,383 46,388

Section 685.309(b)--NSLDS Enrollment Reporting by Institutions

Section 685.309(b) provides that eligible institutions that enroll a Direct Loan borrower must 

report information about the borrower’s enrollment to the Secretary. The Department has 

implemented these provisions by requiring institutions to electronically report, at least twice 

per year, student and loan information to NSLDS. The new Direct Subsidized Loan regulations 

in §685.200(f)(3) provide that a borrower becomes responsible for accruing interest on any 

Direct Subsidized Loans he or she previously received if, after the borrower meets or exceeds 

his or her maximum eligibility period, the borrower enrolls in an undergraduate program of 

equal or shorter duration than the program on which their maximum eligibility period was 

previously based. The new regulations also provide specific rules for borrowers who are 

enrolled in teacher certification programs for which the institution awards no academic 

credential, preparatory coursework necessary for enrollment in a graduate or professional 

program, and programs for which borrowers are not otherwise eligible for Direct Subsidized 

Loans . 

The Department will determine whether the borrower is responsible for accruing interest on 

their previously received Direct Subsidized Loans. To ensure that the Department has the 

information to necessary to make that determination, institutions will be required to report 

additional information to NSLDS. For example, institutions will be required to report: the CIP 

code and the credential level for the program in which a borrower is enrolled; the length of the 
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program in academic years, weeks, or months (consistent with current institutional reporting in 

the COD System); and a more detailed enrollment status of the borrower (e.g., full-time, threequarter-time, half-time, or less-than-half-time).

These data will allow the Department to determine whether a borrower who is not eligible for 

additional Direct Subsidized Loans is responsible for accruing interest on his or her previously 

received Direct Subsidized Loans.

To estimate the total increase in burden imposed on institutions of higher education due to the 

new reporting requirements under §685.309(b), we divided institutions into two groups--

institutions that use enrollment servicers, which are more automated and take less time to 

report enrollment to the Department, and institutions that do not use enrollment servicers and 

therefore take longer to report enrollment to the Department. We assumed that each 

institution that reports enrollment does so twice per year (as minimally required). We estimate 

that the additional reporting will, for institutions using an enrollment servicer, add 0.25 hours 

of burden per report. For institutions that do not use an enrollment servicer, we estimate that 

the additional reporting will add 0.5 hours of additional burden per report.

Of the 8,186 institutions that reported enrollment information during the most recently 

completed award year, 2,710 of them are public institutions. Of the 2,710 public institutions, 

2,092 use enrollment servicers. For the 2,092 public institutions that use enrollment servicers, 

we estimate that additional reporting will add 1,046 hours (2,092 institutions multiplied by 0.25 

additional hours per report, multiplied by 2 reports per year). 

Of the 8,196 institutions that reported enrollment information during the most recently 

completed award year, 2,453 of them are private, not-for-profit institutions. Of the 2,453 

private, not-for-profit institutions, 1,894 use enrollment servicers. For the 1,894 private, notfor-profit institutions that use enrollment servicers, we estimate that additional reporting will 

add 947 hours (1,894 institutions multiplied by 0.25 additional hours per report, multiplied by 2 

reports per year).

Of the 8,196 institutions that reported enrollment information during the most recently 

completed award year, 3,033 of them are proprietary institutions. Of the 3,033 proprietary 

institutions, 2,342 use enrollment servicers. For the 2,342 proprietary institutions that use 

enrollment servicers, we estimate that additional reporting will add 1,171 hours (2,342 

institutions multiplied by 0.25 additional hours per report, multiplied by 2 reports per year). 

Of the 8,186 institutions that reported enrollment information during the most recently 

completed award year, 2,710 of them are public institutions. Of the 2,710 institutions, 618 of 

them do not use enrollment servicers. For the 618 public institutions that do not use 

enrollment servicers, we estimate that additional reporting will add 618 hours (618 institutions 

multiplied by 0.5 additional hours per report, multiplied by 2 reports per year).

Of the 8,196 institutions that reported enrollment information during the most recently 

completed award year, 2,453 of them are private, not-for-profit institutions. Of the 2,453 

private, not-for-profit institutions, 559 of them do not use enrollment servicers. For the 559 
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private, not-for-profit institutions that do not use enrollment servicers, we estimate that 

additional reporting will add 559 hours (559 institutions multiplied by 0.5 additional hours per 

report, multiplied by 2 reports per year).

Of the 8,196 institutions that reported enrollment information during the most recently 

completed award year, 3,033 of them are proprietary institutions. Of the 3,033 proprietary 

institutions, 691 of them do not use enrollment servicers. For the 691 proprietary institutions 

that do not use enrollment servicers, we estimate that additional reporting will add 691 hours 

(691 institutions multiplied by 0.5 additional hours per report, multiplied by 2 reports per year). 

Collectively, as a result of the new reporting requirements, the total burden associated with 

§685.309(b), under 1845-NEW1, will be increased by 5,032 hours (1,046 hours for public

institutions using enrollment servicers + 947 hours for private, not-for-profit institutions using 

enrollment servicers + 1,171 hours for proprietary institutions using enrollment servicers + 618 

hours for public institutions not using enrollment servicers + 559 hours for private, not-forprofit institutions not using enrollment servicers + 691 hours for proprietary institutions that do 

not use enrollment servicers).

4. 34 CFR 685.309(b) - additional reporting to NSLDS

 Individuals

 Private Sector

 Business or other for-profits

Proprietary institutions - additional reporting to NSLDS -

institution uses enrollment servicer

34 CFR 

685.309(b) 2,342 4,684 0.25 1,171

Proprietary institutions - additional reporting to NSLDS -

institution does not use enrollment servicer

34 CFR 

685.309(b) 691 1,382 0.50 691

 Not-for profits

Not-for-profit institutions - additional reporting to NSLDS -

institution uses enrollment servicer

34 CFR 

685.309(b) 1,894 3,788 0.25 947

Not-for-profit institutions - additional reporting to NSLDS -

institution does not use enrollment servicer

34 CFR 

685.309(b) 559 1,118 0.50 559

 State, Local, or Tribal Governments

Public institutions - additional reporting to NSLDS - institution 

uses enrollment servicer

34 CFR 

685.309(b) 2,092 4,184 0.25 1,046

Public institutions - additional reporting to NSLDS - institution 

does not use enrollment servicer

34 CFR 

685.309(b) 618 1,236 0.50 618
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TOTAL 34 CFR 685.309(b) - additional reporting to NSLDS 8,196 16,392 5,032

Section 685.304 – Entrance and Exit Counseling for Borrowers by Institutions

The regulations implement a new statutory requirement that significantly limits a borrower’s 

eligibility for Direct Subsidized Loans and potentially results in the borrower becoming 

responsible for accruing interest on existing Direct Subsidized Loans. Under section 485(l) of 

the HEA, which requires that borrowers be provided with entrance and exit counseling on the 

provisions governing federal student aid, institutions will be required to revise the entrance and 

exit counseling provided to borrowers. 

For entrance counseling, the added counseling requirements under §685.304(a)(6)(xiii) will 

require institutions to explain: (1) the limitation on eligibility for Direct Subsidized Loans and 

the possibility that the borrower will become responsible for accruing interest, as described in 

§685.200(f); (2) the possible loss of eligibility for additional Direct Subsidized Loans;(3) how a 

borrower’s maximum and remaining eligibility periods and subsidized usage period are 

determined; (4) the possible borrower responsibility for accruing interest on previously 

received Direct Subsidized Loans; (5) the borrower’s responsibility for payment of all accruing 

interest on Direct Subsidized Loans during in-school, grace, and periods of authorized 

deferment; (6) and the impact of borrower responsibility for accruing interest on the 

borrower’s total debt.

For exit counseling, the requirements added under new §685.304(b)(4)(xii) will require 

institutions to explain:(1) how maximum and remaining periods of eligibility and subsidized 

usage periods are determined under §685.200(f); (2) the sum of the borrower’s subsidized 

usage periods, as determined under §685.200(f)(1)(iii) following enrollment in or completion of 

the borrower’s most recent educational program; (3) the consequences of continued borrowing 

or enrollment, including the possible loss of eligibility for additional Direct Subsidized Loans and 

the possibility that the borrower could become responsible for accruing interest on previously 

received Direct Subsidized Loans and the portion of a Direct Consolidation Loan that repaid a 

Direct Subsidized Loan, even during in-school periods, grace periods and periods of deferment, 

as described in §685.200(f); (4) the impact of the borrower becoming responsible for accruing 

interest on total student debt; (5) that the Secretary will inform the student borrower of 

whether he or she has become responsible for accruing interest on his or her Direct Subsidized 

Loans; (6) and that the borrower can access NSLDS to determine whether the borrower has 

become responsible for accruing interest on his or her Direct Subsidized Loans, as provided in 

§685.200(f)(3).

The burden associated with entrance and exit counseling is two-fold, there is burden on 

borrowers, who are required to complete entrance counseling by virtue of their participation in 

the Title IV loan programs and there is burden on institutions, which are required to provide 

counseling to such borrowers.
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We estimate that each entrance counseling interview will take 2 additional minutes (0.03 

hours) per borrower to complete and estimated that number of borrowers who took entrance 

counseling in the last award year as 2,723,751. Therefore, we estimate that burden will 

increase by 81,713 hours (2,723,751 borrowers multiplied by 1 interview per borrower 

multiplied by 0.03 additional hours per interview).

We estimate that, for all institutions, the additional entrance counseling requirements will add 

1 hour of burden per institution to incorporate new material into their counseling and 

implement new counseling procedures. Of the 5,847 institutions that are required to perform 

entrance counseling, 1,933 are public institutions, 1,750 are private, not-for-profit institutions, 

and 2,164 are proprietary institutions. For the 1,933 public institutions, we estimate that 

burden will increase by 1,933 hours (1,933 institutions multiplied by 1 hour). For the 1,740 

private, not-for-profit institutions, we estimate that burden will increase by 1,750 hours (1,750 

institutions multiplied by 1 hour). Of the 2,164 proprietary institutions, we estimate that 

burden will increase by 2,164 hours (2,164 institutions multiplied by 1 hour). Collectively, we 

estimate that the total burden created for institutions of higher education to provide the added 

entrance counseling is 5,847 hours (1,933 hours + 1,750 hours + 2,164 hours).

We estimate that each exit counseling interview will take an additional 3 minutes (0.05 hours) 

per borrower to complete and estimated the 2,699,275 borrowers took exit counseling in the

most recently completed award year. Therefore, we estimate that burden will increase by 

134,964 hours (2,699,275 borrowers multiplied by 1 interview per borrower multiplied by 0.05

additional hours per interview).

Of the 5,847 institutions, 1,933 are public institutions, 1,750 are private, not-for-profit 

institutions, and 2,164 are proprietary institutions. We estimate that, for all institutions, the 

additional exit counseling requirements will add 1.5 hours of burden per institution to 

incorporate new material into their counseling and implement new counseling procedures. For 

the 1,933 public institutions, we estimate that burden will increase by 2,900 hours (1,933 

institutions multiplied by 1.5 hours). For the 1,750 private, not-for-profit institutions, we 

estimate that burden will increase by 2,625 hours (1,750 institutions multiplied by 1.5 hours). 

Of the 2,164 proprietary institutions, we estimate that burden will increase by 3,246 hours 

(2,164 institutions multiplied by 1.5 hours). The total burden created for institutions of higher 

education to provide the added exit counseling is 8,771 hours (2,900 hours + 2,625 hours + 

3,246 hours).

Collectively, under 1845-NEW1 the new entrance and exit counseling regulatory requirements 

in section 685.304, will add 231,322 hours ([81,713 + 134,964 for borrowers] + [5,847 + 8,771 

hours for institutions]) of additional burden on institutions and borrowers.

1. 34 CFR 685.304(a)(6)(xii) - entrance 

counseling explaining new provisions 

 Individuals

Students receiving entrance counseling 

explaining new provisions 34 CFR 685.304(a)(6)(xii) 2,723,751 2,723,751 0.03 81,713
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 Private Sector

 Business or other for-profits

Proprietary institutions - provide entrance 

counseling to students explaining new 

provisions 34 CFR 685.304(a)(6)(xii) 2,164 2,164 1.00 2,164

 Not-for profits

Not-for-profit institutions - provide 

entrance counseling to students explaining 

new provisions 34 CFR 685.304(a)(6)(xii) 1,750 1,750 1.00 1,750

 State, Local, or Tribal Governments

Public institutions - provide entrance 

counseling to students explaining new 

provisions 34 CFR 685.304(a)(6)(xii) 1,933 1,933 1.00 1,933

TOTAL 34 CFR 685.304(a)(6)(xii) - exit 

counseling explaining new provisions 2,729,598 2,729,598 87,560

2. 34 CFR 685.304(b)(6)(xii) - exit 

counseling explaining new provisions 

 Individuals

Students receiving exit counseling 

explaining new provisions 34 CFR 685.304(b)(4)(xii) 2,699,275 2,699,275 0.05 134,964

 Private Sector

 Business or other for-profits

Proprietary institutions - provide exit 

counseling to students explaining new 

provisions 34 CFR 685.304(b)(4)(xii) 2,164 2,164 1.50 3,246

 Not-for profits

Not-for-profit institutions - provide exit 

counseling to students explaining new 

provisions 34 CFR 685.304(b)(4)(xii) 1,750 1,750 1.50 2,625

 State, Local, or Tribal Governments

Public institutions - provide exit counseling 

to students explaining new provisions 34 CFR 685.304(b)(4)(xii) 1,933 1,933 1.50 2,900

TOTAL 34 CFR 685.304(b)(6)(xii) - exit 

counseling explaining new provisions 2,705,122 2,705,122 143,734

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.)
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 The cost estimate should be split into two components: (a) a total capital and start-up 

cost component (annualized over its expected useful life); and (b) a total operation 

and maintenance and purchase of services component. The estimates should take 

into account costs associated with generating, maintaining, and disclosing or providing 

the information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such 

as purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out 

information collection services should be a part of this cost burden estimate. In 

developing cost burden estimates, agencies may consult with a sample of respondents 

(fewer than 10), utilize the 60-day pre-OMB submission public comment process and 

use existing economic or regulatory impact analysis associated with the rulemaking 

containing the information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory 

compliance with requirements not associated with the information collection, (3) for 

reasons other than to provide information or keep records for the government, or (4) 

as part of customary and usual business or private practices.

Total Annualized Capital/Startup Cost : 0

Total Annual Costs (O&M) : 0

____________________

Total Annualized Costs Requested : 0

Start-Up Cost Burden to the Respondents

There is no new system start-up costs associated with these proposed regulations.

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.

Estimated Annual Cost to the Federal Government

There are no additional costs to the Federal government as a result of these regulations.
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15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

Reasons for Changes to Burden Hour Estimated

There is no change to the burden hours from the prior iteration of the collection. The burden 

hours calculated below include time for reviewing the change in regulations; for determining 

the method and means to incorporate changes; develop or update systems and forms and 

formats for gathering the required information; and to prepare the required reports. 

# of 

Respondent

s

# of 

Responses

Total 

Hours

TOTAL 34 CFR 685.304(a)(6)(xii) - entrance counseling 

explaining new provisions 2,729,598 2,729,598 87,560

TOTAL 34 CFR 685.304(b)(4)(xii) - exit counseling explaining 

new provisions 2,705,122 2,705,122 143,734

TOTAL 34 CFR 685.301(e) - additional reporting to the COD 

System

5,847 2,319,383 46,388

TOTAL 34 CFR 685.309(b) - additional reporting to NSLDS

8,196 16,392

5,032

Total

5,448,763 7,770,495 282,713

CURRENT INVENTORY`

Current # of Respondents

0

Current # of Responses

0

Current Inventory of Hours

0

REVISED # OF RESPONDENTS

5,448,763

REVISED # OF RESPONSES

7,770,495

REVISED # OF BURDEN HOURS

282,713

TOTAL # RESPONDENTS

5,448,763

TOTAL # RESPONSES

7,770,495

TOTAL # HOURS

282,713

Difference

282,713
OMB 1845-0116

RIN1840-AD11

14

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.

Collection of Information with Published Results

The results of the collection of information will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

Approval to Not Display Expiration Date

The Department is not seeking this approval. The OMB control number and expiration date will 

be announced in the Federal Register upon OMB approval and will also be displayed on the 

Electronic Application for Approval to Participate in Federal Student Financial Aid Programs.

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

Paperwork Reduction Act.

Exception to the Certification Statement

The Department is not requesting any exceptions to the “Certification of Paperwork Reduction 

Act Submissions”.