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OMB Number: 1845-0030 Revised: 03/13/2013

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.

Administrative Requirements and Legislative Authority for the Fiscal Operations 

Report and Application to Participate (FISAP) and the Reallocation Form

FISAP

The Higher Education Opportunity Act (HEOA) (P.L. 110-315) was enacted on August 

14, 2008 and reauthorizes the Higher Education Act of 1965 (HEA), as amended. It 

requires participating Title IV institutions to apply for funds and report expenditures for 

the Federal Perkins Loan (Perkins), the Federal Supplemental Educational Opportunity 

Grant (FSEOG) and the Federal Work-Study (FWS) Programs on an annual basis.

The data submitted electronically in the Fiscal Operations Report and Application to 

Participate (FISAP) is used by the Department of Education (the Department) to 

determine the institution’s funding need for the award year and monitor program 

effectiveness and accountability of fund expenditures. The data is used in conjunction 

with institutional program reviews to assess the administrative capability and 

compliance of the applicant. There are no other resources for collecting this data. 

Sections of the Higher Education Act of 1965, as amended, that govern these programs

can be found at http://www2.ed.gov/about/offices/list/ope/library.html. 

The legislative authority governing the application for the distribution of Perkins funds is 

20 U.S.C. 1087bb (34 CFR 673.3); for FWS funds it is 42 U.S.C. 2752 (34 CFR 673.3); 

and for FSEOG funds it is 20 U.S.C. 107b-3 (34 CFR 673.3).

 

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Please limit pasted text to no longer than 3 paragraphs.
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OMB Number: 1845-0030 Revised: 03/13/2013

The legislative authority governing the annual report on the uses made of funds 

provided under the previous sections is (20 U.S. C. 1094) enacted October 3, 1980, 

P.L. 96-374, sec. 451(a), 94 Stat. 1451; amended April 7, 1986, P.L. 99-272, sec. 

16034, 100 Stat.356; amended October 17, 1986, P.L. 99-498, sec. 487(a), 100 Stat. 

1486.

Reallocation Form

The HEA requires that if an institution anticipates not using all of its allocated funds for 

the Perkins, FWS, and FSEOG programs by the end of an award year, it must specify 

the anticipated remaining unused amount to the Secretary, who reduces the institution’s 

allocation accordingly. Unused amounts are reported in Section A of the Reallocation 

Form.

The HEA also requires the Secretary to reallocate these unexpended funds before the 

appropriations expire on September 30, immediately following their release in this form. 

The data collected in Section B provides the minimum information needed by the 

Secretary to determine a fair and equitable distribution of supplemental FWS allocations 

for the purpose of furthering the program’s community service goals. 

Changes being made to the FISAP and Reallocation Form Collections

The forms and instructions are rolled over annually to accommodate the next cycle. 

The deadline dates and award year references are being updated. 

In addition to annual award year and date references, significant changes are being 

made to three key areas as explained below. 

 Part I, Section A, item 5. Additional Institutions

This item was formerly identified as “Additional Locations.” However, we have 

discovered an unintended misuse of terminology which resulted in some schools 

incorrectly interpreting this item and providing incorrect information. This item is to 

be used by an institution that is reporting, on one FISAP, information for not only 

itself but also for other institutions that, while having different OPEIDs are under the 

same administrative control or ownership as he reporting institution.

We have changed the eCB system to require less data entry by institutions by using 

technology to gather existing data electronically from other sources.

 Part II, Section D and F, Non-Traditional Calendar Enrollment Information

A non-traditional calendar means a school admits a new group of students monthly, 

or more frequently, into a majority of its eligible programs—even if those students 

enroll on a quarter, trimester, or semester basis. Currently the FISAP only requests 

“non-traditional” schools to provide undergraduate enrollment. 
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OMB Number: 1845-0030 Revised: 03/13/2013

At one time this was appropriate because a non-traditional school’s level of degree 

tended to range from certificates to associate degrees or to other undergraduate 

credentials. However, there are now institutions offering programs above the 

undergraduate level using non-traditional calendars. In order for these schools to 

accurately represent their graduate enrollment on the FISAP form, we are expanding 

Lines 9-22 of Part II, Section D to include columns (c) and (d), for graduate 

enrollment. 

This change was discussed with OMB staff on 11/26/2012 with concurrence 

received on 11/30/2012.

 Part VI, Section A, Distribution of Program Recipients and Expenditures by

Type of Student

To provide for more precise statistical analysis, the income grid in this section has 

been expanded to include $10,000 increments over the current $60,000 limit up to 

$100,000 and over, and for Undergraduate Dependent students $5,000 increments 

over the current $20,000 up to $40,000 and over. 

There is minimal additional burden to schools as these expanded fields have the 

same edits as the existing fields where data is required and a null value is not 

accepted.

This change was requested by OMB staff during the previous year review of this 

data collection. Discussions were held 8/21/2012 with concurrence on 8/24/2012.

There are no data items being changed on the Reallocation Form.

In addition to annual award year and date references, the FISAP Instructions are being 

updated to correct some minor typographical errors and clarify instructions as described 

by part:

FISAP 

Instructions 

Part

Description

Introduction  Page iii – Provided additional information concerning Additional 

Institutions.

 Page v – Updated Campus-Based deadline dates and funding 

schedule.

Part I  Section A. Field 1(a) – Explained need for additional information if

the school is a new applicant for 2014-2015 but its students were 

included in a FISAP filed by a different school last year.
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OMB Number: 1845-0030 Revised: 03/13/2013

 Section A. Field 5 – Revised Additional Institution data entry 

information.

Part II  Section A. Introduction – Added note to explain that if a school’s 

Program Participation Agreement does not reflect eligibility for a 

specific Campus-Based program; data cannot be entered to request 

funds for that program.

 Section C. Field 6 - Provided additional information concerning 

Waiver of the FWS/FSEOG institutional-share requirement for Title 

III/V Schools.

 Section D. Fields 7 & 8 – Provided clarification that High School 

students who are also enrolled in postsecondary classes are not 

“regular” students and are not to be reported as enrolled for the 

purposes of the FISAP.

 Section D. Fields 9-21 – Provided clarification concerning enrollment 

information for a school with a non-traditional calendar

Part III  No changes.

Part IV  No changes.

Part V  No changes.

Part VI  No changes.
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OMB Number: 1845-0030 Revised: 03/13/2013

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.

FISAP

The relative institutional financial need, which is the basis for computing by formula the 

amount of funds needed by each institution to operate one or more of the CampusBased Programs during the application year, is determined by the data reported in the 

form. The data is used to assess program effectiveness and accountability of fund 

expenditures under the previously cited authority. In addition, the data is used in 

conjunction with institutional program reviews to help assess the administrative 

capability of the applicant and enforce compliance.

a) Application data provides a standard measure of institutional need used to 

distribute a level of funds for institutions requesting participation in one or more of 

the Campus-Based Programs.

b) Application data provides a data base that is sufficient, comprehensive and 

reliable to calculate annual funding formulas based on verifiable data input.

c) Expenditure data is used to calculate past utilization of funds awarded for 

assessment of penalties, recovery of unexpended funds, and close-out of 

awards.

d) Data regarding Perkins Loan collection activities are used to compute institutional 

cohort default rates, compile the Federal Perkins Loan Status of Default (Orange 

Book), and to track issuance of Perkins Loan cancellations for teaching; military; 

volunteer; law enforcement and corrections officer; child, family and early 

intervention; nurse and medical technician; pre-K or child care; public defender; 

fire fighter; Tribal College faculty; librarian; and speech pathology services.

e) Data is maintained and made readily available to Department staff and other 

agencies for analysis, historical research, budget evaluations, audits, program 

reviews, and OIG inquiries.

f) The eCB system processes all FISAP on the Web information in real-time into 

the database. Institutions with outstanding (required) hard-copy signature forms 

are automatically identified to withhold funding until the forms have been 

received and validated.

g) The data collected is used to identify poorly administered operations that may 

require on-site monitoring, additional training of staff, or termination of funding in 

extreme cases.
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OMB Number: 1845-0030 Revised: 03/13/2013

The information collected in this submission enables the Department to comply with 

legislation that authorizes and appropriates funds for the Campus-Based Programs.

Reallocation Form

The unexpended funds reported in the Reallocation Form are distributed by the 

Department as supplemental awards to qualifying institutions in accordance with 

provisions of the HEA. FWS funds will be awarded to eligible institutions that used at 

least seven percent of their total FWS funds to compensate students employed as 

reading tutors to children or in family literacy activities as part of their community-service 

activities. Because FWS reallocated funds are distributed on a fair-share basis, 

institutions must have a fair-share shortfall to receive these funds. Institutions use the 

reallocated (supplemental) funds to compensate students employed in community 

service. Legislation requires the unexpended funds to be reported and redistributed. 

Collection of this information maximizes utilization of the appropriated funds, provides 

financial aid to needy students, and results in the Department’s compliance with the 

reallocation provisions of the HEA.

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.

For the upcoming award year, institutions will continue to use the Department’s 

electronic services to participate in the Title IV Programs. Institutions participating in the 

Campus-Based Programs must submit FISAP and campus-based funds reallocation 

data through eCB at https://cbfisap.ed.gov. The certification signature page is printed 

locally from eCB.

eCB processing of both the FISAP and the Reallocation Form has eliminated printing 

costs, distribution, expense, data entry time, and reduced the cycle time and input 

errors. This process reduces institutional burden by using three years of information 

already contained in the database to provide institutional characteristics to verify funding 

levels and reduce the number of staff necessary to process the information.
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OMB Number: 1845-0030 Revised: 03/13/2013

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.

FISAP

No other agency or system collects the information needed to determine the allocation 

of campus-based funds. 

It had been anticipated that some Perkins data could be retrieved from NSLDS. 

However, as currently designed, it does not collect Perkins interest data and the timing 

of the submission of Perkins data to the Department through NSLDS and the manner in 

which it is collected limit its use as a substitute for Perkins reporting on the FISAP. 

Section A of the Perkins Loan Report (FISAP, Part III) contains 89 cells of data. Section 

C contains 28 data cells. NSLDS does not contain sufficient historical information to 

populate the cells in these two sections which require data to be cumulative from the 

beginning of an institution’s participation in Perkins. Section B of the Perkins Loan 

Report has 15 data cells. Two cells (loans advanced to students during the report year 

and principal and interest repaid by the borrowers for the same year) could conceivably 

be populated with data from NSLDS. Sections D and E contain Perkins cohort default 

rate data, which is not currently available from NSLDS. Review of the data needed for 

completion of the five sections of the Perkins Loan Report and the data available in 

NSLDS concludes that NSLDS data will not currently provide data that is compatible 

with either the historical or annual data collected on the FISAP. 

FSEOG overpayment data is collected in NSLDS, but no FSEOG disbursement data is 

collected. No FWS data is collected in NSLDS. 

NSLDS does not and cannot collect data that would sufficiently correspond to the type 

of data required from the FISAP for items such as annual award calculations, cohort 

default rate calculations, cumulative collections data, and prior year account 

reconciliation data. At this time, institutions will continue to be required to provide FISAP 

data in order for the Department to carry out required functions such as the calculation 

of allocations and Perkins cancellation reimbursements.

Reallocation Form

Similar information as is collected on the Reallocation Form is not available at the time it 

is needed. The Department must rely on the information being required by institutions 

at the end of each award year (June 30). The reporting and redistribution must be 

complete prior to September 30, or the authority to obligate these funds will expire. 
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OMB Number: 1845-0030 Revised: 03/13/2013

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 collection of this information does not involve small businesses or other small 

entities. Information is collected from Title IV eligible schools only.

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.

FISAP

If the FISAP data collection were not conducted or conducted less frequently, the 

Department would not be in compliance with authorizing legislation or appropriation 

legislation which requires annual distribution of appropriated funds on the basis of an 

annual application from eligible institutions.

Reallocation Form

If the data collection on the Reallocation Form were not conducted or conducted less 

frequently, the authority to redistribute the excess funds would expire on September 30 

and the Department would not meet the legislative requirement to reallocate funds.

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;
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OMB Number: 1845-0030 Revised: 03/13/2013

 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.

There are no special circumstances inconsistent with these guidelines.

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.

FISAP

Campus-Based staff members in both operations and policy areas provide 

presentations and support for national and regional conferences. During these 

activities, staff members take all comments, recommendations, and suggestions made 

by institutions for use in determining the need for improvement or change to existing 

policies and procedures.

Frequent communication with institutions by our Call Center and Campus-Based staff 

provides additional information on the data being collected and on problems with 

electronic processing requirements. Comments from schools are shared with staff 

members and frequently included as possible upgrades to existing procedures. 

Institutions continue to report favorably about the ease in completing and submitting the 

data electronically.
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OMB Number: 1845-0030 Revised: 03/13/2013

The Department’s OMB clearance process allows further opportunity for comment on 

the FISAP through an announcement in the Federal Register at the onset of the 

clearance process. The Department accepts public comments on the FISAP during a 

60-day time period. Revisions are made to the documents as deemed necessary based 

on the comments. An additional 30-day comment period is provided through another 

announcement in the Federal Register. Historically, institutions rarely submit comments 

on the FISAP. The Campus-Based Programs have been in operation for more than 40 

years, and completion of the annual FISAP is a common practice for institutions.

Reallocation Form

The reporting of unexpended funds by institutions participating in the Campus-Based 

Program is required by the HEA. Institutions submit part of this information annually in 

the FISAP at a later date. The collection of this data is frequently discussed a financial 

aid conferences, and the financial aid community provides unsolicited comments 

through their contacts with our Call Center and Campus-Based staff members.

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

remuneration of contractors or grantees with meaningful justification.

There are no payments or gifts to respondents other than the allocation of Federal funds 

that result from the information collected.

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 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 about the confidentiality of the data.

 

2

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

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

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

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

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

of Personally Identifiable Information)
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OMB Number: 1845-0030 Revised: 03/13/2013

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.

No questions of a sensitive nature are asked.

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.

FISAP

The FISAP data collection is composed of six parts. Part I is the institution’s 

identification. Part II is the application for funds. Part III is the Federal Perkins Loan 

Report. Part IV is the FSEOG Report. Part V is the FWS Report. Part VI is the 

Program Summary. The range of time required to complete the various parts of the 

form depends on several variables: (1) the number of programs in which respondents 
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OMB Number: 1845-0030 Revised: 03/13/2013

are currently participating; (2) whether the respondent is a “first-time” or “continuing” 

applicant; and (3) the type of institution.

Burden hours for new schools are minimal since they are only required to complete the 

first two parts (Identifying Information, Certification and Warning; and the Application to 

Participate).

Proprietary institutions use less time to prepare the FISAP than public and private 

institutions. A random sampling of institutions revealed that proprietary institutions were 

more likely to use servicers to prepare their FISAP. Since servicers prepare FISAPS in 

volume, they tend to keep their computerized data systems updated, and have totally 

encompassed the Department’s electronic processes into their systems which results in 

less FISAP preparation time.

Most public and private institutions have restructured their data collection processes so 

that information is readily accessible to complete the FISAP electronically. Identifying 

information is pre-populated on the FISAP from prior year data and common 

mathematical computations are automatically displayed, which reduces institutional 

burden. Data entry and process edits notify users of erroneous data entry or potential 

data issues. This assists the data entry, reduces review time, and also reduces 

institutional burden.

The matrix below shows the respondent participation from the most recent FISAP 

submission (October 1, 2012) in the various parts of the submission. The total amounts 

shown by institutional type are unduplicated counts. The part breakdowns under each 

category of Institution are duplicated counts, based on the variables described above.
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OMB Number: 1845-0030 Revised: 03/13/2013

FISAP Respondent 

Type by Part

Estimated 

Number of 

Respondents

Estimated 

Person Hours 

per 

RespondentReporting

Estimated 

Person Hours 

per 

RespondentRecord 

Keeping Total Hours

Total Hours

(AVG Person 

hrs x Resp)

Public

Parts I & II -

Application 1549 2.0 2.0 4.0

Part III - Federal 

Perkins Loan 748 4.0 4.0 8.0

Part IV - FSEOG 1526 2.0 2.0 4.0

Part V - FWS 1496 2.0 2.0 4.0

Part VI - Summary 1538 2.0 2.0 4.0

Total Number 

Respondents

Total Hours 

per 

RespondentReporting

Total Hours 

per 

RespondentRecord 

Keeping

Total Hours 

per 

Respondent

Total Annual 

Burden Hours 

- All 

Respondents

Total FISAP 

Respondents -

Public Schools 1549 12.0 12.0 24.0 37,176

Proprietary

Parts I & II -

Application 1057 2.0 2.0 4.0

Part III - Federal 

Perkins Loan 194 3.0 3.0 6.0

Part IV - FSEOG 976 1.0 1.0 2.0

Part V - FWS 503 1.0 1.0 2.0

Part VI - Summary 976 1.0 1.0 2.0

Total 1057 8.0 8.0 16.0 16,912

Private (NonProfit)

Parts I & II -

Application 1457 3.0 3.0 6.0

Part III - Federal 

Perkins Loan 998 4.0 4.0 8.0

Part IV - FSEOG 1319 1.0 1.0 2.0

Part V - FWS 1360 2.0 2.0 4.0

Part VI - Summary 1419 1.0 1.0 2.0

Total 1457 11.0 11.0 11.0 32,054

Total Number 

Respondents

Total Avg. 

Hours per 

RespondentReporting

Total Avg. 

Hours per 

RespondentRecord 

Keeping

Total Avg. 

Hours per 

Respondent

Total Annual 

Burden Hours 

- All 

Respondents

Total FISAP 

Respondents -

Proprietary & 

Private (NonProfit) Schools 2514 9.5 9.5 19.0 47,766

Because both the FISAP and the Reallocation form contain separate Paperwork Burden 

Statements that contain an estimated average number of hours for completion, the 
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OMB Number: 1845-0030 Revised: 03/13/2013

complex averages demonstrated above for the FISAP have been combined into the 

total annual burden hours for all respondents and divided by the total number of 

respondents. The estimated average number of hours for completion of the FISAP has 

been calculated to be 20.91 hours per respondent.

Total Number 

Respondents

Total Annual 

Burden Hours 

- All 

Respondents

Total Burden

Hours per 

Each 

Respondent

(84942/4063)

FISAP Total 4063 84942 20.91
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OMB Number: 1845-0030 Revised: 03/13/2013

Reallocation Form

The Reallocation Form data collection is composed of two sections. Section A requests 

unexpended allocation figures for the Campus-Based Programs. Section B requests 

information regarding supplemental FWS funds. The range of time required to complete 

the two sections of the form depends on these variables: (1) the number of programs in 

which respondents are currently participating; and (2) whether or not an institution 

requests supplemental funds for community service activities.

The following matrix shows the respondent participation from the most recent 

Reallocation Form submission (August 17, 2012) in the two sections of the form. The 

amounts shown are unduplicated counts. 

Reallocation Form 

by Respondent Type 

Estimated 

Number of 

Respondents

Estimated 

Person Hours 

per 

RespondentReporting

Estimated 

Person Hours 

per 

RespondentRecord 

Keeping Total Hours

Total Hours

(AVG Person 

hrs x #Resp)

Public

Section A 28 .5 .5 1.0

Section B 34 .5 .5 1.0

Total Number 

Respondents

Total Hours 

per 

Respondent -

Reporting

Total Hours 

per 

Respondent -

Record 

Keeping

Total Hours 

per 

Respondent

Total Annual 

Burden Hours 

- All 

Respondents

Total Reallocation 

Respondents -

Public Schools 62 1.0 1.0 2.0 124

Proprietary

Section A 74 .5 .5 1.0

Section B 6 .5 .5 1.0

Total 80 1.0 1.0 2.0 160

Private (NonProfit)

Section A 30 .5 .5 1.0

Section B 23 .5 .5 1.0

Total 53 1.0 1.0 2.0 106

Total Number 

Respondents

AVG Total 

Hours per 

Respondent -

Reporting

AVG Total 

Hours per 

Respondent -

Record 

Keeping

AVG Total 

Hours per 

Respondent

Total Annual 

Burden Hours 

- All 

Respondents

Total Reallocation 

Respondents -

Proprietary & 

Private (NonProfit) Schools 133 1.0 1.0 2.0 266

Because both the FISAP and the Reallocation form contain separate Paperwork Burden 

Statements that contain an estimated average number of hours for completion, the 
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OMB Number: 1845-0030 Revised: 03/13/2013

complex averages demonstrated above for the Reallocation Form have been combined 

into the total annual burden hours for all respondents and divided by the total number of 

respondents. The estimated average number of hours for completion of the 

Reallocation Form has been calculated to be 2.0 hours per respondent.

Total Number 

Respondents

Total Annual 

Burden Hours 

- All 

Respondents

Total Burden 

Hours per 

Each 

Respondent

(84942/4063)

Reallocation Form 

Total 195 390 2.0

Total Burden FISAP and Reallocation Forms

The combined total for the FISAP and Reallocation Form has an estimated total of 4258 

respondents with a total annual burden of 85,322 hours. We’ve used the Census

Bureau National Industry-Specific Occupational Employment Wage Estimate for 

Educational Services (NAICS 611300 Colleges, Universities, and Professional Schools, 

Occupation Code 13-119) of $25.48 per hour, the estimated total to all respondents of 

$2,174,260.

The matrix below shows the combined totals for the separate data provided in the 

FISAP and Reallocation data matrices above as well as the estimated Hour-Burden

Salary Cost to respondent institutions.
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OMB Number: 1845-0030 Revised: 03/13/2013

Summary of Burden FISAP & Reallocation (1845-0030)

Program Change

Requested

Due to New 

Statute

Due to Office 

Discretion

Due to Adj. in 

Office Estimate

Change Due 

to 

Potential 

Violation

Currently 

Approved

Annual 

Number of 

Responses

FISAP-Public 1,549

FISAPProprietary 

& Non-Profit 2,514

Reallocation 

Form-Public 62

Reallocation 

FormProprietary 

& Non-Profit 133

Total 4,258 0 0 0 0 4,258

Annual Hour 

Burden

FISAP-Public 37,176

FISAPProprietary 

& Non-Profit 47,766

Reallocation 

Form-Public 124

Reallocation 

FormProprietary 

& Non-Profit 266

Total 85,322 0 52,371 0 0 32,961

Annual 

Salary Cost 

FISAP-Public $947,244

FISAPProprietary 

& Non-Profit $1,217,078

Reallocation 

Form-Public $3,160

Reallocation 

FormProprietary 

& Non-Profit $6,778

Total $2,174,260 0 $2,174,260 0 0 0
18

OMB Number: 1845-0030 Revised: 03/13/2013

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 startup 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 : 

The nature of business for Title IV institutions (the respondents) is such that purchases 

of equipment and provision of services that are required for electronic processing of the 

FISAP and Reallocation form are a part of their customary and usual business practice. 

They are the type of equipment and services normally necessary to successfully 

operate any educational entity.
19

OMB Number: 1845-0030 Revised: 03/13/2013

The requirement to transmit the FISAP and Reallocation Form data electronically 

through eCB is not considered an increase in burden for most institutions. Because 

thousands of institutions are already participating in other Title IV, they would have 

access to the Internet (web) in order to do business with the Department.

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 matrix below describes the separate costs for the FISAP and the Reallocation Form 

and the combined total annual cost to the Federal Government of $2,600,735.00.

FISAP

FISAP Cost for Development of eCampus-Based FISAP on the Web

Many tasks must be performed in order to develop the FISAP on the 

Web and make it available to campus-based participants. Some of 

the major costs include the costs for contractor services, the 

development of web server programs, the Technical Reference, 

documents for posting on the web (i.e. Electronic Announcements), 

and the FISAP Form and Instructions Booklet. The amount below 

reflects the cost all of these campus-based programs to the 

Department. There are no funds designated for Development at 

this time.

Total $0

FISAP Publication and Distribution Costs

The FISAP on the Web cost is replacing the old Publication & 

Distribution Cost calculation because it is no longer needed.

Total $0

FISAP Operations & Maintenance Contract Costs

Collabralink

3130 Fairview Park Drive

Suite 800

Falls Church, VA 22042 

The cost of collecting and maintaining the data is justified 

because FISAP data is made available to, and widely used, 

throughout the Department for analysis, historical research, 

budget evaluations, audits, program reviews, OIG inquiries, etc. 

In addition, the information collected justifies institutional 

funding for the next award period.

The current annual O&M costs for the eCB system include the FISAP 

and Reallocation forms as well as the TCLI Directory*, Work 
20

OMB Number: 1845-0030 Revised: 03/13/2013

Colleges Application and Expenditure forms**, and the CTPIntellectual disabilities form***. 

*The TCLI Directory is a separate data collection with OMB 

control number 1845-0077.

**The number of schools participating in the Work Colleges 

program is static at 7 participants. There is no OMB control 

number for this data collection.

***The CTP is a separate data collection with OMB control number 

1845-0113.

Note:

Annual O&M Contract cost - $1,402,344 = monthly cost $116,862

allotted as:

FISAP (8 months) = $934,896

Reallocation (1 month) = $116,862

TCLI Directory (1 month) = $116,862

Work Colleges (1 month) = $116,862

CTP-Intellectual Disabilities (1 month) = $116,862

Total (8 months) $934,896

FISAP Staffing Operations and Overhead Costs

A staff of 7.75 FTE’s is required for the operation of the 

campus-based programs and the eCB system. This includes the 

FISAP and Reallocation forms as well as the TCLI Directory, Work 

Colleges Application and Expenditure forms, and the CTPIntellectual disabilities form as footnoted on page 18. As the 

driving force in these operations, the FISAP is the instrument by 

which institutions request campus-based funding and report 

program expenditures. The FISAP provides the data that is 

required to perform a variety of processes such as funding 

calculations, program compliance, analysis, customer service, 

information publication and distribution, accounting and fund 

control, etc. The types of program staff include managers, 

accountants, financial management specialists, technicians, 

systems analysts, and clerical staff. 

Using the Salary Table 2012-DCB Effective January 2012, the 

average hourly wage of the current staff composition is $46.94. 

Note:

The total amount of annual salaries devoted eCB activities is 

divided as:

Reallocation (3 staff @ 120 hrs ea x $46.94) = $16,899.30

TCLI Directory (1 staff @ 80 hrs x $46.94) = $3,755.40
21

OMB Number: 1845-0030 Revised: 03/13/2013

Work Colleges (1 staff @ 160 hrs x $46.94) = $7,510.80

CTP-Intellectual Disabilities (1 staff @ 160 hrs x $46.94) = 

$7,510.80

FISAP (Total salaries less Reallocation, TCLI Directory, Work 

Colleges, CTP-Intellectual Disabilities) = $1,318,425.70

Yearly Staff Costs $1,318,425.70

FISAP Yearly Overhead Costs

A standard budget estimate of 16% was used to determine the 

overhead costs of staff operations including such items as 

equipment, utilities, work materials, etc. ($1,318,425.70 x 16% = 

$210,948.11)

Yearly Overhead Costs $ 210,948.11

Total Staff and Overhead Costs $1,529,373.81
22

OMB Number: 1845-0030 Revised: 03/13/2013

Reallocation Form

Reallocation Form Publication and Distribution

Publication and distribution cost to the campus-based programs 

has been eliminated. The conversion to the eCampus-Based FISAP on 

the web has transferred all costs, including software production 

and distribution, into the overall contract for services made by 

the Department.

Total $0

Reallocation Form Operations & Maintenance Contract Costs

Collabralink

3130 Fairview Park Drive

Suite 800

Falls Church, VA 22042 

Total (1 month) $ 116,862.00

Reallocation Form Staffing Operations and Overhead Costs

A staff of 3 is required for the operation of the campus-based 

programs Reallocation process. While the FISAP is the instrument 

by which institutions request campus-based funding and report 

program expenditures, the Campus-Based Reallocation Form is used 

to provide information that is needed prior to the annual 

submission of the FISAP. 

The 3 program staff members include managers, accountants and 

systems analysts. Of that staff, each of the three employees 

worked 120 hours per year on the Reallocation process for a total 

of 360 hours worked for the office. This process takes 

approximately two half-months to complete for a yearly cost of 

$16,899.30 (120 hours x 3 employees x $46.94 average hourly 

rate). 

Yearly Staff Costs $ 16,899.30

Reallocation Form Yearly Overhead Costs

A standard budget estimate of 16% was used to determine the 

overhead costs of staff operations including such items as 

equipment, utilities, work materials, etc. ($16,899.30 x 16% = 

$2,703.89)

Yearly Overhead Costs $ 2,703.89

Total Staff and Overhead Costs $ 19,603.19
23

OMB Number: 1845-0030 Revised: 03/13/2013

FISAP and Reallocation Form Combined Total Cost to 

Federal Government

Cost for Development of eCB FISAP on the Web $ 0.00

O&M Costs to the Federal Government $1,051,758.00

Staff Operations and Overhead Costs $1,548,977.00

Total $2,600,735.00

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).

The total annual reporting and record keeping hour burden changed from the current 

OMB inventory of 32,961 to 85,332 (an increase of 52,371 hours) due to an increase in 

the number of fields on the form, a change in the composition of respondents from the 

different types of Title IV institutions on various sections of the forms and mathematical 

errors made previous to automation of the calculations by implementation of ICRAS at 

the Department of Education.

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.

This information collected on the FISAP and the Reallocation form is not collected for 

statistical publication

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.
24

OMB Number: 1845-0030 Revised: 03/13/2013

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.