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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

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 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.

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 employment (GE) program, 

whereas Subpart N establishes an institutional cohort default rate.

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 program cohort default rate is a measure the Department uses to determine the 

eligibility of a GE program under Subpart 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 submits a “challenge” after it receives

its draft program cohort default rate, and the institution requests 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 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.

Institutions would use a combination of institutional systems and Departmental systems 

to report data to the Department and receive data from the Department.

 

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Please limit pasted text to no longer than 3 paragraphs.
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

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.

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 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.

No small businesses are affected by this information 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.

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 underlying 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 quarterly;

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

fewer than 30 days after receipt of it;

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

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

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

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

results than can be generalized to the universe of study;

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

approved by OMB;

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

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

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

agencies for compatible confidential use; or
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

 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 that the Department has published the 60 and 30 Federal Register notices 

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

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

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

comments received on cost and hour burden.

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

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

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

reported.

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

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

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

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

The 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 package will run 

concurrently with the Notice of Proposed Rulemaking.

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

of contractors or grantees with meaningful justification.

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. If personally identifiable information (PII) is 

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

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

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

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

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

 

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

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

about the confidentially of the data.

The Department makes no pledge of confidentiality regarding the data.

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 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)

 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.

Section 668.504(b) – Draft cohort default rates and your ability to challenge before 

official program cohort default rates are issued, incorrect data challenges.

Under proposed 668.504(b), the institution may challenge the accuracy of the data 

included on the Loan Record Detail Report (LRDR) by sending an incorrect data 

challenge to the relevant data manager(s) within 45 days of receipt of the LRDR from the 

Department. The challenge would include a description of the information in the LRDR 

that the institution believes is incorrect along with supporting documentation.
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

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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 incorrect data challenges would be 4 hours (1.5 hours for list review and 2.5 

hours for documentation submission). This would increase burden by 4,728 hours.

We estimate that out of the likely 1,285 submissions, 39 (3 percent) would be from 

private non-profit 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 submission). This would increase burden by 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 by 256 hours. 

Collectively, this would increase burden by 5,140 hours under OMB Control Number 

NEW3.

Section 688.504(b) - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

1,285 1,285 4 5,140

Section 668.504(c) – Draft cohort default rates and your 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 IV 

eligibility, if the institution’s participation rate would be equal to or less than 0.0625 for 

any of the three pCDR fiscal years that where the pCDR is 30 percent or greater. A 

participation rate index challenge (and a participation rate index appeal for final rates, 

discussed below) could be submitted if the number of students who received title IV, 

HEA program loans during a one-year period was only a small percentage of those who 

were eligible to borrow.

Based upon FY 2011 submissions, there were 2 participation rate 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 the
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

1,863 includes 920 programs with rates between 20.0 percent and 29.9 percent that are

not subject to loss of eligibility and only the 943 failing programs that are subject to loss 

of eligibility can submit a participation 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 nonprofit 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 by 8 hours (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 688.504(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 calculate 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 uncorrected 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 adjustments 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 data adjustments would 

be from private non-profit institutions. Therefore, burden would increase at private nonprofit institutions by 9 hours (6 adjustments times 1.5 hours) under OMB Control 

Number 1845-NEW3. 
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

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 LRDR for the official rates show that 

data have been newly included, excluded, or otherwise changed and the errors are 

confirmed by 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 documentation submission, for a total of 4 hours. 

We 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 hours) 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 times 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 hours) 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 76
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

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Section 668.512 Loan 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 payment on the loan and the 

institution can prove that 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 the 

projected 943 challenges, adjustments, and appeals are projected to be loan servicing 

appeals. We estimate that, on average, to gather, analyze, and submit the necessary

documentation, each appeal would take 3 hours.

We estimate that 35 (92 percent) of 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 percent) 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 estimate 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 increase 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 rate 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.
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

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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 

economically disadvantaged appeals. We estimate that preparing and submitting an 

economically disadvantaged appeal would take an institution 5 hours for each program.

We estimate that 8 (92 percent) of the 9 projected economically disadvantaged appeals 

would be from for-profit institutions. Therefore, burden would increase at for-profit 

institutions by 40 hours (8 programs times 5 hours) under OMB Control Number 1845-

NEW3.

We do not project any 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 §668.513 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 any of those three program cohort’s fiscal 

years. 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-year period was only a small percentage 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, adjustments, 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.

We 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.
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

Section 688.514 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 4 4 2 8

SUMMARY:

Currently Approved Numbers:

# 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

 1,289 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 76

Section 688.512 - New Burden:

# of Respondents # of Responses Hours/Response 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 5,717
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ICRAS Number: (2015) 1845-NEW3 Revised: 03/10/14

RIN Number: 1840-AD15 

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

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

Discussions with institutional representatives related to estimated costs for the surveys or 

use of State sponsored data systems 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 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.

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.
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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 

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

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

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

burden hours, responses and costs (if applicable).

This is a new information collection due to program changes that are 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 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.

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 Department 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 any exceptions to the “Certification for Paperwork 

Reduction Act Submissions” of OMB Form 83-1.