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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

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

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

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

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

Section 487(c) of the Higher Education Act (HEA) of 1965, as amended requires that the 

Secretary of Education prescribe regulations to ensure that any funds postsecondary institutions 

receive under the HEA are used solely for the purposes specified in and in accordance with the 

provision of the applicable programs. The concept of this federal gatekeeping has a long history, 

originating in 1952. However, as a result of abuses by institutions in the Title IV programs, the 

HEA amendments of 1992 significantly increased ED’s gatekeeping responsibilities. In general, 

the statutory provisions tightened the eligibility requirements for institutions participating in the 

student financial assistance programs authorized under Title IV of the HEA. 

In 1994, the Secretary amended the regulations governing institutional eligibility under 

the HEA in accordance with the statutory requirements. The Institutional Eligibility regulations 

govern the initial and continuing eligibility of postsecondary educational institutions 

participating in the student financial assistance program authorized by Title IV of the HEA. 

Part H, Subpart 3, Section 498 of the HEA of 1965, as amended, gives the Secretary the 

responsibility for determining qualifications of institutions of higher education to participate in 

programs under the HEA. To comply with this requirement Section 498(b) of the HEA specified 

that the Secretary prepare and prescribe a single application form. The Department developed 

the Application for Approval to Participate in the Federal Student Financial Aid Programs to 

comply with the statutory requirements of collecting necessary information under the HEA. 

An institution must use this Application to apply for approval to be determined to be 

eligible and if the institution wishes, to participate; to expand its eligibility; or to continue to 

participate in the Title IV programs. An institution must also use the application to report certain 

required data as part of its recordkeeping requirements contained in the regulations under 34 

CFR Part 600 (Institutional Eligibility under the Higher Education Act of 1965, as amended). 

 

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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

The Department uses the information reported on the Application in its determination of 

whether an institution meets the statutory and regulatory requirements.

Listed below are the specific regulations that require an institution to apply to the 

Department of Education for:

 An eligibility determination and if requested, certification to participate;

 Continued eligibility to participate;

 Reporting changes made to the institution, as required; and

 Expansion of its current approval.

Section 600.20 - Application procedures - requires an institution that wishes to participate 

in any Title IV program, to apply for initial eligibility, as well as continued or expanded approval 

including new locations or new programs. 

Section 600.21 – Updating Application Information - requires an institution to notify the 

Secretary of any changes to certain information, including its name, address, etc.

Section 600.31 - Change in ownership resulting in a change of control - requires an 

institution that has undergone a change in ownership that results in a change in control to 

demonstrate to the Secretary that it meets the requirements of an eligible institution in order to 

continue to be eligible. The 1998 Amendments provided that the Secretary may continue the 

institution’s participation on a provisional basis provided that the institution under the new 

ownership submits a materially complete application that is received by the Secretary no later 

than 10 business days after the change occurs. 

In addition to the information above, the application is also the place where schools can 

report other information to us that it needs or wants us to know. For example, the Higher 

Education Act of 1965 (HEA), as amended, requires an institution of postsecondary education to 

file a disclosure report with the Secretary on January 31 or July 31 of each year, containing 

certain information about gifts received from or contracts entered into with foreign sources or 

about ownership or control of the institution by a foreign source (Section 1209, 20 U.S.C. 

1145d). 

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 School Eligibility Service Group, (the organization within the Department of 

Education, Federal Student Aid, responsible for providing integrated oversight to postsecondary

schools) reviews and analyzes the information reported on the application and makes a 

determination on the institution’s request. The School Participation Division’s (SPD) decision 

to approve an institution’s request for Title IV program eligibility only (in the case of an 

institution of higher education that does not plan to participate in our Title IV programs, 

however, it wishes for its students to be eligible for in-school deferments while in attendance), or 

Title IV eligibility and participation is based not only on the information reported by the 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

institution on the application, but also on other information in the team’s possession. SPD makes 

its decision using a case team approach to its work processes. This allows SPD to evaluate a 

school based on a total picture of integrated institutional information. 

SPD’s decision includes determining that the institution:

 Is designated an eligible institution; 

 Is certified or recertified to participate in Title IV programs;

 Is approved, for Title IV purpose, to expand its current approval (new location or new 

programs, etc.); 

 Met its reporting requirements and we have updated our records (changes to name or 

address, etc.); or

 Is denied eligibility, certification or approval of its expansion for purposes of Title IV. 

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

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

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

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

technology to reduce burden.

The data submitted by an institution during the initial round of certification became part 

of the Postsecondary Education Participants System (PEPS), the Department of Education's 

computerized information management system of institutional data. Subsequently, the School 

Eligibility Service Group designed a computerized version of the Application. An institution 

accesses the Application using the Internet. Many of the questions on the Application are prepopulated using information the institution submitted on its previous Application, which is stored 

in PEPS. Pre-populating the answers to the questions reduces burden for the institution and 

alleviates the need for the institution to enter a response to every question. Instead, the 

institution needs to review the pre-populated information and if necessary, update it. (Note: 

Certain questions must be answered each time an institution submits a complete application.) 

Once the institution has completed its updates to the Application, the updated application is 

submitted to the School Eligibility Service Group via the Internet. The institution receives 

immediate notification of receipt by the Department. Once the Department makes its decision to 

approve or to deny the Application, the information from the Application is migrated to PEPS 

electronically, thus reducing the Department’s burden for data entry as well as increasing the 

accuracy of the data in PEPS.

The electronic application has additional features such as:

 Hot links to take the user from one area to another in one mouse click; 

 Skip features that skip questions or a section if it does not apply to the institution;

 Edits that help the institution not miss a required question or enter the wrong type of 

information;

 A Help section; 

 ED contacts, both phone numbers and e-mail address. The e-mail address is actually a 

hot link directly to SPT or PEPS and allows an institution to submit its questions to the 

Department electronically; and 

 A status page that tells the institution where the application is in SPT’s review process.
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

System of Record Notice: 18-11-09 -- 64 FR 30171-30173, June 4, 1999

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.

Institutions are not required to maintain duplicate records. The Application for Approval 

to Participate in the Federal Student Financial Aid Programs provides the initial contact of an 

institution seeking to participate in Federal programs administered by Federal Student Aid. A 

new institution will not have provided similar information to any other office in the Department. 

While a continuing institution may have provided similar information as part of the Integrated 

Postsecondary Education Data System (IPEDS) survey, the Application information provided is 

not necessarily the same.

5. If the collection of information impacts small businesses or other small entities, describe any 

methods used to minimize burden. A small entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently

owned and operated and is not dominant in its field; or (3) a small government jurisdiction, 

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

The information collection does not impact small businesses or other small entities.

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

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

burden.

Section 498(g) of the HEA requires that the Department recertify all eligible institutions 

that wish to continue to participate in the Title IV programs. The maximum time period the 

Secretary may approve an institution is up to 6 years.

The statute also provides that the Secretary may provisionally certify new institutions, 

institutions that change ownership, and institutions with questionable financial responsibility and

administrative capability for a period of time from one to three years. The Department uses 

provisional approval as a tool to allow for increased monitoring of institutions with no track 

record and institutions with documented problems. If information were collected less frequently, 

ED would not be in compliance with the HEA and would not be using the tools Congress 

provided to improve gatekeeping capability.

Note that it is not necessary for an institution to submit a complete application to report 

activities such as change in name or address, a change in level of course offering or a change in 

measurement of program length. Instead, with the Application, institutions need to update only 

the questions on the Application that are affected by the change. Thus, while the frequency with 

which institutions must report certain changes has not changed and cannot, because they are vital 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

pieces of information relative to the institution's eligibility, the reporting burden for those actions 

is decreased significantly.

If the collection is not conducted, a new institution would not be able to participate in 

Title IV programs, a currently approved institution would not be able to participate past its 

approved expiration date, meet the notification and recordkeeping requirements or be able to 

expand its eligibility. Further, the Department would lose a valuable gatekeeping tool.

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

in a manner:

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

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

fewer than 30 days after receipt of it;

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

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

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

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

results than can be generalized to the universe of study;

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

approved by OMB;

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

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

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

agencies for compatible confidential use; or

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

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

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

This collection of information does not meet any of the special circumstances described 

above.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to 

submission to OMB. Summarize public comments received in response to that notice and 

describe actions taken by the agency in response to these comments. Specifically address 

comments received on cost and hour burden.

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

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

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

reported.

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

who must compile records should occur at least once every 3 years – even if the collection of 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

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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.

We will publish 60-day and 30-day Federal Register notices to seek public comment. There 

were no comments received for the 60-day Federal Register. We will publish a 30-day Federal 

Register notice for public comments. 

The Application has been widely accepted by the community and has been in use in its 

current form since September of 1996. The current form was created after a focus group of 

industry professionals (redesign group) worked with the Department to address the higher 

education community’s concerns about complexity, length, and burden regarding the previous 

version of the Application. The goals of improving the clarity, accuracy and simplicity of the 

Application while still allowing the Department to improve gatekeeping, have a more efficient 

process, receive more reliable information from the institution, and provide for institutional 

accountability, produced a valuable tool that asks clear questions that do not burden institutions.

The Department holds a conference each Fall devoted to the effective and efficient 

administration of the Title IV, HEA programs. The Application is one of the processes that are 

featured at these conferences. Responses received from school officials continue to be extremely

positive. The feedback provided by users indicates that the questions in the Application are clear 

and that the process to complete the Application is simple. 

In addition, Department officials routinely attend state, regional and professional 

association meetings and conferences. Typically, the Department participates in these forums as 

an opportunity to receive feedback from the higher education community regarding its policies 

and procedures including the Application and the recertification process. The feedback 

continues to overwhelming approve the Application in part, due to the reduction of data 

collection burden. 

In addition to attending meetings and conferences, the Department also receives feedback 

from the community via telephone calls and e-mails. The Department has been responsive to 

these comments and suggestions from the community. We continued to make changes to 

improve the Application, which make it even easier to use.

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

of contractors or grantees with meaningful justification.

None

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

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

The Application includes a Privacy Act Notice that (1) informs the institution of the 

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

is voluntary, but if the institution chooses not to submit an Application for Approval to 

Participate in Federal Student Financial Aid Programs, the institution cannot be determined to be 

eligible or continued to be eligible for the Title IV, HEA programs, and (3) identifies the third 

parties to whom the information may be disclosed.

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

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

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

This collection does not ask questions of a sensitive nature.

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

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

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

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

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

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

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

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

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

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

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

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

not include burden hours for customary and usual business practices.

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

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

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

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

 

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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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

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 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.

34 CFR

Requirement

Number of 

Respondents3

Number of 

Responses/

Applications 

Reported Annually

Hours Required 

to Collect and 

Report

Total Hours

600.20 

Initial 

Applications–

Affected Entities

For-Profit 

Institutions

70 70 17 1,190

Not-for-Profit 

Institutions

13 13 17 221

Public Institutions 3 3 17 51

Sub-total 86 86 17 1,462

600.20 

Recertification –

Affected Entities

For-Profit 

Institutions

488 488 10 4,880

Not-for-Profit 

Institutions

455 455 10 4,550

Public Institutions 477 477 10 4,770

Sub-total 1,420 1,420 10 14,200

600.20 Foreign 

Recert – Affected 

Entities

For-Profit 

Institutions

2 2 15 30

Not-for-Profit 

Institutions

29 29 15 435

Public Institutions 137 137 15 2,055

Sub-total 168 168 15 2,520

 

3 Many institutions report more than once a year, therefore a single respondent could be counted 

under several of the required regulatory reporting areas. As a result, the unduplicated number of 

respondents is a number smaller than the sum of the sub-totals – see below.
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

34 CFR

Requirement

Number of 

Respondents3

Number of 

Responses/

Applications 

Reported Annually

Hours Required 

to Collect and 

Report

Total Hours

600.20

Expanded 

Eligibility –

Affected Entities

 

For-Profit 

Institutions

330 647 1 647

Not-for-Profit 

Institutions

244 244 1 244

Public Institutions 596 1,168 1 1,168

Sub-total 1,170 2,059 1 2,059

600.21

Updating 

Eligibility –

Affected Entities

For-Profit 

Institutions

1,026 1,477 1 1,477

Not-for-Profit 

Institutions

 696 1,002 1 1,002

Public Institutions 703 1,012 1 1,012

Sub-total 2,425 3,491 1 3,491

600.31

Change in 

Ownership –

Affected Entities

 

For-Profit 

Institutions

53 53 10 530

Not-for-Profit 

Institutions

9 9 10 90

Public Institutions 0 0 10 0

Sub-total 63 62 10 620

Total Responses 5,331

1 7,286

 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

34 CFR

Requirement

Number of 

Respondents3

Number of 

Responses/

Applications 

Reported Annually

Hours Required 

to Collect and 

Report

Total Hours

Total 

Unduplicated 

Respondents 

 4,9832

Total Hour Burden of Collection Information 24,352

600.20 Refers to applications submitted by institutions for initial approval, reinstatement, 

recertification and expansion of its current eligibility. This requirement has been broken 

down into four lines since it takes a new school longer to complete an initial application 

than one that is submitting a recertification application. As explained earlier, the 

electronic application is pre-populated with information the Department previously

received from the institution. Further, an institution applying for expansion of its current 

eligibility only needs to complete the portion of the application that applies to the 

expansion, so it takes much less time to complete that type of application.

600.21 Refers to the requirement that institutions must update the Department regarding certain 

required information such as changes to the institution’s name or address.

600.31 Refers to applications submitted for change in ownership that result in the change of 

control.

This burden information was estimated based on recent (FY 2012) conversations with 

institutions that have submitted applications for these various purposes.

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

information, identifying and using appropriate wage rate categories. 

600.20 Initial Applicant

Position Wage Rate

Category

Cost Per

Hour

Hours Expended Cost

Burden

Senior

Administrator

$200,956 $97 1 $97

Professional

Staff

$62,800 $30 16 $480

Total 17 $577

1 Many institutions respond more than once a year, therefore a single respondent could be counted under several of 

the required regulatory reporting areas. As a result, the unduplicated number of respondents is a number smaller 

than the sum of the sub-totals.

600.20 Recertification

 

2 The unduplicated number of Respondents.
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

RIN Number: XXXX-XXXX (if applicable)

Position Wage Rate

Category

Cost Per

Hour

Hours Expended Cost

Burden

Senior

Administrator

$200,956 $97 1 $97

Professional

Staff

$62,800 $30 9 $270

Total 10 $367

600.20 Recertification of Foreign Institution

Position Wage Rate

Category

Cost Per

Hour

Hours Expended Cost

Burden

Senior

Administrator

$200,956 $97 1 $97

Professional

Staff

$62,800 $30 14 $420

Total 15 $517

600.20 Request to Expand Eligibility

Position Wage Rate

Category

Cost Per

Hour

Hours Expended Cost

Burden

Senior

Administrator

$200,956 $97 .40 $39

Professional

Staff

$62,800 $30 .60 $ 18

Total 1 $57

600.21 Update Changes 

Position Wage Rate

Category

Cost Per

Hour

Hours Expended Cost

Burden

Senior

Administrator

$200,956 $97 .40 $39

Professional

Staff

$62,800 $30 .60 $ 18

Total 1 $57

600.31 Change in Ownership

Position Wage Rate

Category

Cost Per

Hour

Hours Expended Cost

Burden

Senior

Administrator

$200,956 $97 1 $97

Professional

Staff

$62,800 $30 9 $270

Total 10 $367
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

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Annualized	Cost	for	Collection	of	Information	

34 CFR

Requirement

Number of Institutions 

Reporting Annually4

Cost per Institution Total Burden

600.20 

Initial

109 $577 $62,893

600.20 

Recertification

1412 $367 $518,204

600.20

Foreign Recert

87 $517 $44,979

600.20

Expand Eligibility

1,266 $57 $72,162

600.21 1,497 $57 $85,329

600.31 114 $367 $41,838

Total Annualized Cost per Application for Institutions $825,405

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden shown 

in Items 12 and 14.)

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

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

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

costs associated with generating, maintaining, and disclosing or providing the 

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

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

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

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

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

equipment; and acquiring and maintaining record storage facilities.

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

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

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

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

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

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

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and

usual business or private practices. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

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Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There is no cost burden to respondents or record-keepers resulting from the information 

collection other than shown in items 12 and 14. The total government expense for capital and 

start up costs for this Information Collection is zero.

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.

REVIEWERS COSTS: Identifies the amount of time for a reviewer to examine the 

information submitted on the application and the supporting documentation. This information is 

then reported out to the team for a full decision on the institution’s application.

34 CFR

Requirement

Number of 

Institutions 

Reporting 

Annually

Hours 

Required for 

ED Review

Total Hours Average

Hourly

Wage

Cost per CFR 

Requirement

600.20 

Initial

109 2 218 $34 $7,412

600.20 

Recertification

1,412 2 2,824 $34 $96,016

600.20 

Foreign Recert

87 3 261 $34 $8,874

600.20

Expand Eligibility

1,266 1 1,266 $34 $43,044

600.21 1,497 .5 749 $34 $25,466

600.31 114 2 228 $34 $7,752

ED Cost to review of the Application information $188,564

ED Cost to maintain system and improve electronic Application: $450,000

Total Annualized Cost to the Federal government: $638,564

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 
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ICRAS Tracking and OMB Number: (1393) 1845-0012 Revised: 11/8/2013

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should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

There have been no significant program changes. The change in hours is due to a change in the 

number of applications projected. There is an anticipated decrease in Initial applications and 

Change in Ownership applications, while all other types of applications are expected to increase. 

The decrease in new institutions and in the buying and selling of existing institutions is likely

due to the current economic conditions in the United States. As for the increases, Recertification 

applications are submitted shortly before an institution’s current eligibility expires and can 

therefore be reasonably projected. The increase in applications for Expanded and Updated 

Eligibility likely results from continued improvement in the understanding of the application 

process, more consistent compliance with our reporting requirements, and institutions being 

more responsive to economic changes resulting in more changes to locations and educational 

programs.

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.

Application information is not expected to 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.

The Department will display the expiration date for the OMB approval on the form.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.