1

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5

**SUPPORTING STATEMENT**

**FOR PAPERWORK REDUCTION ACT SUBMISSION PROGRAM COHORT DEFAULT RATE**  **(pCDR) A. Justification**  1. Explain the circumstances that make the collection of information necessary . Identify any legal or administrative requirements that necessitate the collection. Attach a hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1 . Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The Secretary

proposed to amend the Student Assistance General Provisions by adding Subpart R to 34 CFR Part 668. Proposed Subpart R is new and mirrors Subpart N

– Cohort Default Rates where applicable. Subpart R establishes a programmatic cohort default rate as one of the qualitative metrics for gainful employ ment ( GE ) program, whereas Subpart N establishes an institutional cohort de fault rate. 2. I ndicate 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 program cohort default rate is a measure the Department use s to determine the eligibility of a GE program under S ubpart R of 34 CFR part. This subpart describes how program cohort default rates (pCDR) are calculated, some of the consequences of pCDRs , and how institutions may request changes to their pCDRs or appeal the consequences. Under this subpart, the institution submit s a “challenge” after it receive s its draft program cohort default rate, and the institution request s an “adjustment” or “appeal” after its official program cohort default rate is published. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection te chniques or forms of information technology , e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. Institutio ns would use a combination of institutional sy stems and Departmental sy stems to report data to the Department and receive data from the Department.
1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y availa

ble cannot be used or modified for use for the purposes described in I tem 2 above. The current requirements avoid duplication. There is no similar information available that can be used or modified for this purpose at this time. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not - for
- profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city , count y, town, township, school district, or special district with a population of less than 50,000. No small businesses are affected b y this information collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducte d less frequentl y, as well as an y technical or legal obstacles to reducing burden. Absent this proposed data collection , enrolled students and prospective students would not have sufficient information to make informed decisions about whether to start or continue in a particular GE program. Also, institutions would not have a method to challenge or adjust the underly ing data used to calculate the pCDR and programs could lose eligibility

and student could lose access to previously eligible programs without due process. 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 quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 contrac t, grant - in
- aid, or tax records for more than three y ears;  in connection with a statistical survey , that is not designed to produce valid and reliable results than can be generalized to the universe of study ;  requiring the use of a statistical data classif ication that has not been reviewed and approved b y OMB;  that includes a pledge of confidentiality that is not supported by

authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent wi th the pledge, or that unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or3

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5

 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. The collection of this information will continue to be conducted in a manner that is consistent with the guidelines in 5 CFR 1320.6. 8. As applicable, state t hat the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describ e actions taken b y 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 an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or tho se who must compile records should occur at least once every 3 y ears
– 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. Th e proposed regulations were developed through the Negotiated Rulemaking process where the public provided its input and in consultation with schools, and other affected entities. The comment period for the information collection pa ckage will run concurrently

with the Notice of Proposed Rulemaking
. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. No pay ments or gifts will be provided to the respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy . If personally

identifiable information (PII) is being collected, a Privacy Act sta tement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authoriz es the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality
. If

2 Requests for this inform ation are in accordance with the follow ing ED and OMB policies: Privacy Act of 1974, OMB Circular A
- 108

– Privacy Act Implementation

– Guidelines and Responsibilities, OMB Circular A
- 130 Appendix I

– Federal Agency Responsibilities for Maintaining Re cords 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 P ersonally Identifiable Information)4

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. The Department makes no pledge of confidentiality regarding the data. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, r eligious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y t he agency considers the questions necessary , the specific uses to be made of the information, the explanation to be given to person s from whom the information is requested, and an y steps to be taken to obtain their consent. The Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for
- profit, private sector

– not - for
- profit institutions, farms, state, local or tribal governments), frequency of respon se, annual hour burden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widel y because of differenc es in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual business practices.  If this request for approval covers mo re than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)  Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outside parties for information collection a ctivities should not be included here. Instead, this cost should be included in I tem 14. Section 668. 50 4 (b)

– Draft cohort default rates and y our ability to challenge before official program cohort default rates are issued, incorrect data challenges. U nder proposed 668.504(b), the institution may challenge the accuracy

of the data included on the Loan Record Detail Report ( LR DR ) by sending an incorrect data challenge to the relevant data manager(s) within 45 day s of receipt of the LRDR from the Departme nt. The challenge would include a description of the information in the L RDR that the institution believes is incorrect along with supporting documentation.5

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 Based upon FY 2011 submissions, there were 353 institutional CDR challenges for incorrect data of a total of 510 challenges, requests for adjustments, and appeals, a 69 percent submission rate. Therefore 69 percent of the projected 1,863 challenges, adjustments, and appeals, or 1,285, are projected to be challenges for incorrect data. We estimate that out of the likely 1,285 submissions, 1,182 (92 percent) would be from for
- profit institutions. We estimate that the average institutional staff time needed to review a GE program’s LRDR for each of these 1,182 programs and to gather and prepare incor rect data challenges would be 4 hours (1.5 hours for list review and 2.5 hours for documentation submission). This would increase burden b y 4,728 hours. We estimate that out of the likely 1,285 submissions, 39 (3 percent) would be from private non
- profi t institutions. We estimate that the average institutional staff time needed to review a GE program’s LRDR for each of these 39 programs and to gather and prepare the challenges would be 4 hours (1.5 hours for list review and 2.5 hours for documentation s ubmission). This would increase burden b y 156 hours. We estimate that, out of the likely 1,285 submissions, 64 (5 percent) would be from public institutions. We estimate that the average institutional staff time needed to review a GE program’s LRDR for each of these 64 programs and to gather and prepare the challenges would be 4 hours (1.5 hours for list review and 2.5 hours for documentation submission). This would increase burden b y 256 hours. Collectively , this would increase burden b y 5,140 hours under OMB Control Number NEW3. Section 688.504(b)
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 1, 2 8 5 1, 2 85 4 5,140 Section 668.504( c )

– Draft cohort default rates and y our ability to challenge before official program cohort default rates are issued, participation rate index challenges
. Under proposed 668.504(c), institutions may challenge an anticipated loss of title I V eligibility , i f the institution’s participation rate would be equal to or less than 0.0625 for any of the three pCDR fiscal y ears that where the pCDR is 30 percent or greater. A participation rate index challenge (and a participation rate index appeal for final rates, d iscussed below) could be submitted if the number of students who received title I V, HEA program loans during a one
- ye ar period was only a small percentage of those who were eligible to borrow. Based upon FY 2011 submissions, there were 2 participation rat e index challenges of the total 510 challenges, requests for adjustments, and appeals 0.4 percent. Therefore we project that there will be 4 participation rate challenges (0.4 percent of the projected 943 challenges, adjustments, and appeals). Note that we use 943 and not 1,863 because the6

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 1,863 includes 920 programs with rates between 20.0 percent and 29.9 percent that are not subject to loss of eligibility and onl y the 943 failing programs that are subject to loss of eligibility

can submit a participati on rate index challenge. Further, based upon GE program distribution percentages, we project that all 4 participation rate index challenges would be from for
- profit institutions. Therefore, all of the estimated burden below would be to for
- profit institutions and none to private non
profit or public institutions. On average, we estimate that gathering and submitting the information for each participation rate challenge would take 2.0 hours per submission. Therefore, burden would increase b y 8 hou rs (4 participation rate index challenges times 2 hours per submission) under OMB Control Number 1845
- NEW3. The total increase in burden for §668.504 would be 5,148 hours under OMB Control Number 1845
- NEW3. Section 688. 50 4( c )
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 4 4 2 8 Section 668. 509
- Uncorrected data adjustments. An institution may

request an uncorrected data adjustment for the most recent cohort of borrowers used to c alculate a GE program’s most recent official pCDR, if in response to the institution’s incorrect data challenge, a data manager agreed to change data but the changes were not reflected in the official pCDR. Based upon FY 2011 submissions, there were 116 u ncorrected data adjustments of the total 510 challenges, requests for adjustments, and appeals. Therefore, 23 percent of the projected 943 challenges, adjustments, and appeals (based on possible loss of eligibility ) or 217 are projected to be uncorrected data adjustments. We estimate that the average institutional staff time needed is 1 hour for list review and 0.5 hours for documentation submission, for a total of 1.5 hours. We estimate that 200 (92 percent) of the 217 projected uncorrected data adjust ments will be from for
- profit institutions. Therefore, burden would increase at for
- profit institutions by 300 hours (200 adjustments times 1.5 hours) under OMB Control Number 1845
- NEW3. We estimate that 6 (3 percent) of the 217 projected uncorrected d ata adjustments would be from private non
- profit institutions. Therefore, burden would increase at private non
profit institutions by

9 hours (6 adjustments times 1.5 hours) under OMB Control Number 1845
- NEW3.7

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 We estimate that 11 (5 percent) of the 217 projected uncorrected data adjustments would be from public institutions. Therefore, burden would increase at public institutions by 17 hours (11 adjustments times 1.5 hours) under OMB Control Number 1845
- NEW3. The total increase in burden for §668.509 would be 326 hours under OMB Control Number 1845
- NEW3. Section 688. 509
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 217 217 1.5 326 Section 668. 510

– New data adjustments. An institution could request a new data adjustment for the most recent cohort of borrowers used to calculate the most recent official pCDR for a GE program, if a comparison of the LRDR for the draft rates and the L RDR for the official rates show that data have been newl y included, excluded, or otherwise changed and the errors are confirmed b y the data manager. Based upon FY 2011 submissions, there were 12 new data adjustments of the total 510 challenges, requests for adjustments, and appeals. Therefore, 2 percent of the projected 943 challenges, adjustments, and appeals (based on possible sanction) or 19 are projected to be new data adjustments. We estimate that the average institutional staff time needed is 3 hours for list review and 1 hour for document ation submission, for a total of 4 hours. W e estimate that 17 (92 percent) of the 19 projected new data adjustments would be from for
- profit institutions. Therefore, burden would increase at for
- profit institutions by 68 hours (17 adjustments times 4 ho urs) under OMB Control Number 1845
- NEW3. We estimate that 1 (3 percent) of the 19 projected new data adjustments would be from private non
- profit institutions. Therefore, burden would increase at private non
- profit institutions by

4 hours (1 adjustment t imes 4 hours) under OMB Control Number 1845
- NEW3. We estimate that 1 (5 percent) of the 19 projected new data adjustments would be from public institutions. Therefore, burden would increase at public institutions by 4 hours under (1 adjustment times 4 ho urs) OMB Control Number 1845
- NEW3. The total increase in burden for §668.510 would be 76 hours under OMB Control Number 1845
- NEW3. Section 688. 510
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 19 19 4 768

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 Section 668.512 L oan Servicing appeals. An institution could appeal the calculation of a pCDR on the basis of improper loan servicing or collection only if the borrower did not make a pay ment on the loan and the institution can prove t hat the servicer failed to perform required loan servicing or collections activities. Based upon FY 2011 submissions, there were 19 loan servicing appeals of the total 510 challenges, requests for adjustments, and appeals. Therefore, 4 percent or 38 of t he projected 943 challenges, adjustments, and appeals are projected to be loan servicing appeals. We estimate that, on average, to gather, analy ze, and submit the necessary documentation, each appeal would take 3 hours. We estimate that 35 (92 percent) o f the 38 projected loan servicing appeals would be from for
- profit institutions. Therefore, burden would increase at for
- profit institutions by 105 hours (35 servicing appeals times 3 hours) under OMB Control Number 1845
- NEW3. We estimate that 1 (3 perce nt) of the 38 projected loan servicing appeals would be from private non
- profit institutions. Therefore, burden would increase at private non
- profit institutions by

3 hours (1 servicing appeal times 3 hours) under OMB Control Number 1845
- NEW3. We estimat e that 2 (5 percent) of the 38 projected loan servicing appeals would be from public institutions. Therefore, burden would increase at public institutions by 6 hours (2 servicing appeals times 3 hours) under OMB Control Number 1845
- NEW3. The total increa se in burden for §668.512 would be 114 hours under OMB Control Number 1845
- NEW3. Section 688.512
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 38 38 3 114

Section 668.513
- Economically disadvantaged appeals. An institution could appeal a notice of a sanction under §668.410 or a notice of a second successive official pCDR that is equal to or greater than 30 percent if an independent auditor certifies that the low income rat e for the GE program is two
- thirds or more and the program is a degree program with a completion rate of 70 percent or more or, if the program is not a degree program, its placement rate is 44 percent or more.9

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 Based upon FY 2011 submissions, there were 6 economically disadvantaged appeals of the total 510 challenges, requests for adjustments, and appeals. Therefore 9 (1 percent) of the projected 943 challenges, adjustments, and appeals are projected to be economicall y disadvantaged appeals. We estimate th at preparing and submitting an economicall y disadvantaged appeal would take an institution 5 hours for each program. We estimate that 8 (92 percent) of the 9 projected economicall y disadvantaged appeals would be from for
- profit institutions. Therefore, b urden would increase at for
- profit institutions by

40 hours (8 programs times 5 hours) under OMB Control Number 1845
- NEW3. We do not project an y economically disadvantaged appeals from the private non
- profit institutions. We estimate that 1 (5 percent) of the 9 projected economically disadvantaged appeals would be from public institutions. Therefore, burden would increase at public institutions by 5 hours (1 program times 5 hours) under OMB Control Number 1845
- NEW3. The total increase in burden for §6 68.513 would be 45 hours under OMB Control Number 1845
- NEW3. Section 688.513
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 9 9 5 45 Section 668.514 Participation rate index appeals. An institution could appeal a notice of loss of title IV eligibility under §668.410 based upon two pCDRs of 30 percent or greater if the participation rate index for that GE program is equal to or less than 0.0625 for an y of those three program cohort’s fi scal ye ars. A participation rate index appeal (and a participation rate index challenge for draft rates, discussed above) could be submitted if the number of students who received title IV , HEA program loans during a one
- ye ar period was only a small perce ntage of those who were eligible to borrow. Based upon FY 2011 submissions, there were 2 participation rate index appeals of the total 510 challenges, requests for adjustments, and appeals. Therefore 0.4 percent of the projected 943 challenges, adjustmen ts, and appeals or 4 are projected to be participation rate index appeals. On average, we estimate that gathering and submitting the information for each appeal would take 2 hours per submission. W e estimate that all 4 projected participation rate index appeals would be from for
- profit institutions. Therefore, the total increase in burden for §668.514 would be 8 hours (4 participation rate index appeals times 2 hours) under OMB Control Number 1845
- NEW3.10

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 Section 688.514
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 4 4 2 8 SUMMARY: Currently Approved Number s : # of Respondents # of Responses Hours/Response Burden Hours 0 0 0 New Burden : Section 688.504
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 1, 2 89 1,289 5,148 Section 688.509
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours 217 217 326 Section 688.510
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours

19 19 7 6 Section 688.512
- New Burden : # of Respondents # of Responses Hours/R esponse Burden Hours

38 38 114 Section 688.513
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours

9 9 45 Section 688.514
- New Burden : # of Respondents # of Responses Hours/Response Burden Hours

4 4 8 Revised Numbers Requested : # of Respondents # of Responses Hours/Response Burden Hours 1,576 1,576 5,71711

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5
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 I tems 12 and 14.)

 The cost estimate should be split into two com ponents: (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, mai ntaining, and disclosing or providing the information. I nclude descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period ov er which costs will be incurred. Capital and start - up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.  If cost estimates are expected to vary widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part of this cost bu rden 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 anal ys is 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 n ot associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : Discussions with institutional representatives related to estimated costs for the survey s or use of State sponsored data sy stems would be conducted after the NPRM is published and prior to the final regulation’s publication to inform the cost estimate. 14. Provide estimates of annualiz ed 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 w ould not have been incurred without this collection of information. Agencies also may aggregate cost estimates from I tems 12, 13, and 14 in a single table. The cost to the federal government will be determined following the discussions above that occur after the NPRM and prior to the final regulations’ publication.12

ICRAS Number : ( 2015 ) 1845
- NEW 3 Revised: 0 3 / 10 /1 4 RIN Number: 1840
- AD 1 5 15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result from re
- estimating burden and/or from economic phenomenon outside of an agency ’s contr ol (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materiall y changes a collection of information and generally are result of new statute or an agency a ction (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), t ype of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)
. This is a new information collection due to program changes that ar e a result of the addition of Subpart R of 34 CFR Part 668. The program changes are due to agency discretion upon completion of Negotiated Rulemaking sessions. 16. For collections of information whose results will be published, outline plans for tabulati on and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other a ctions. The results of this 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. The Departme nt is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83
- 1.