1

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

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

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

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

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

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

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

of the sections or changed sections, if applicable.

Section 493C of the Higher Education Act of 1965, as amended (the HEA), authorizes the 

Income-Based Repayment (IBR) Plan and for borrowers who obtain student loans through the 

Federal Family Education Loan (FFEL) Program and William D. Ford Federal Direct Loan 

(Direct Loan) Program. Sections 455(d) of the HEA, authorizes Income-Contingent Repayment 

(ICR) Plan for borrowers who obtain student loans through the Direct Loan Program.

The regulations that govern the IBR plan in 34 CFR 682.215 and 685.221. The regulations that 

govern the ICR Plan are in 34 CFR 685.209. In accordance with 34 CFR 682.209(a)(6)(iii) and 

685.210(a)(1), a FFEL Program lender or the Secretary must offer a borrower a choice of certain 

repayment plans, including the IBR Plan, and, in the case of the Direct Loan Program, the ICR 

Plan.

Section 493C(b) of the HEA and the regulations provide that a borrower may choose to repay his 

or her loans under the IBR Plan only if the borrower has a partial financial hardship. A borrower 

is considered to have a partial financial hardship if the annual amount due on his or her eligible 

loans, as calculated under a standard repayment plan based on a 10-year repayment period, 

exceeds 15% of the difference between the borrower’s adjusted gross income (AGI) and 150% of 

the HHS poverty guideline for the borrower’s family size and state of residence. If a borrower 

has a partial financial hardship, the maximum monthly amount that a borrower may be required 

to repay under the IBR Plan is 15% of the difference between the borrower’s AGI and 150% of 

the applicable HHS Poverty Guideline, divided by 12. A loan holder determines whether a 

borrower has a partial financial hardship to qualify for the IBR plan for the year the borrower 

initially selects the IBR Plan and for each subsequent year that the borrower remains on the plan.

 

1

Please limit pasted text to no longer than 3 paragraphs.
2

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

The Department, on July 17, 2012, published a Notice of Proposed Rulemaking in the Federal 

Register (77 FR 42085) to change the ICR plan by splitting ICR into two variants (ICR-A and 

ICR-B). 

 One variant (ICR-B), is the same as the ICR Plan in current Direct Loan regulations, 

where a borrower’s payment amount is the lesser of what the borrower would pay (1) on 

a 12-year amortization of his or her Direct Loans multiplied by an income percentage 

factor or (2) 20 percent of the difference between the borrower’s AGI and 100% of the 

HHS poverty guideline for the borrower’s family size and state of residence.

 The other variant (ICR-A), is the same as the IBR Plan in current Direct Loan 

regulations, except that when evaluating whether the borrower has a partial financial 

hardship, the Secretary will evaluate the borrower’s 10-year standard repayment amount 

against and calculate a borrower’s payment amount to be 10% of the difference between 

the borrower’s AGI and 150% of the HHS poverty guideline for the borrower’s family

size and state of residence. ICR-A will only be available to Direct Loan borrowers who 

(1) have no outstanding balance on a Direct Loan or FFEL program loan as of October 1, 

2007 or have no outstanding balance on a Direct Loan or FFEL program loan when 

obtaining a new loan on or after October 1, 2007, and (2) receive a disbursement of a 

Direct Subsidized Loan, Direct Unsubsidized Loan, or student Direct PLUS Loan on or 

after October 1, 2011, or receive a Direct Consolidation Loan based on an application 

received on or after October 1, 2011.

Regulations also require a borrower who wishes to repay under the IBR or ICR Plan to annually 

provide his or her loan holder with AGI by the Internal Revenue Service (IRS) to the loan holder. 

A borrower must also annually certify his or her family size.

If a borrower’s AGI is not available, or if the borrower’s loan holder believes that the borrower’s 

current AGI does not reasonably reflect the borrower’s current income, regulations provide that a 

loan holder may use alternative documentation of income provided by the borrower for purposes 

of determining whether the borrower has a partial financial hardship and calculating the IBR or 

ICR Plan monthly payment amount.

The Department is revising this collection to combine it with the IBR and ICR-related 

information on the Direct Loan Repayment Plan Selection Form (1845-0014) and the IBR/ICR 

Alternative Documentation of Income (1845-0016), and reflect the proposed ICR-A variant. The 

revised collection also merges both forms that were associated with 1845-0102 into one form. 

The revised collection adds a variety of checkboxes and skip logic, which are intended to 

streamline the completion of the form, and help borrowers request the IBR or ICR Plan 

determine whether the loan holder requires specific information, e.g., a spouse’s identifiers, to 

process the borrower’s request. Through the combing of multiple forms and streamlining, the 

Department estimates that the amount of time necessary per respondent to complete the revised 

from has decreased from 1.33 hours to 0.33 hours. Therefore, though the number of respondents 

increasing is a natural consequence of combining multiple forms into one, there is a significant 

reduction in overall burden to respondents.
3

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

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 currently approved forms are used by borrowers to request the IBR or ICR Plan on their 

loans, and they also collect the information that is required for the Department to determine 

whether the borrower meets the eligibility requirements or repayment amount for the requested 

IBR or ICR Plan. The revised deferment request forms will continue to be used for these 

purposes. 

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.

This collection will also be adapted for use on the Internet, so that borrowers may request the 

IBR or ICR Plan via the Department’s StudentLoans.gov website, and import information 

regarding their income from the Internal Revenue Service, if available. At first, the adaptation 

will only cover the IBR Plan and only certain loan holders who request to participate; however, it 

will later be expanded to include the ICR Plan. In the event that the borrower cannot import 

their income information from the Internal Revenue Service, the borrower will be able to 

complete the rest of the form electronically, print it, sign it, attach the necessary supporting 

documentation, and sent it to the borrower’s loan holder.

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.

There is no information already available from other sources that can be used to establish a 

borrower’s eligibility or payment amount for an IBR or ICR Plan. However, by combing and 

streamlining multiple collections about the IBR and ICR Plan, borrowers will only need to 

complete one form for all loan holders, regardless of their circumstances.

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.
4

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

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.

The frequency with which a borrower requests an IBR or ICR Plan is determined in accordance 

with statutory and regulatory requirements that are explained on the form. Less frequent data 

collection would not allow loan holders to process borrower requests for an IBR or ICR Plan. 

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

in a manner:

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

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

fewer than 30 days after receipt of it;

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

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

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

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

results than can be generalized to the universe of study;

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

approved by OMB;

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

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

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

agencies for compatible confidential use; or

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

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

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

This information collection does not involve any of the conditions listed in 5 CFR 1320.5(d)(2).

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.
5

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

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 forms included with this submission were originally developed with input from schools, 

guaranty agencies, servicers, lenders, and borrower advocacy groups. In developing the revised 

forms included with this submission, the Department considered recommendations from its 

Direct Loan servicers.

A notice was published in the Federal Register on August 8, 2012 soliciting comment for 60 

days. The Department received a number of comments, and accepted nearly all of the comments

from the community. Another notice will be published in the Federal Register soliciting public 

comments for 30 days. 

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 were or will be provided to 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 

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

about the confidentially of the data.

The form includes a Privacy Act Notice that (1) informs the borrower of the statutory authority

for the information collection, (2) explains that providing the requested information is voluntary, 

but is required in order request an IBR or ICR Plan, and (3) identifies the third parties to whom 

the information collected on the form may be disclosed, and explains the circumstances under 

 

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)
6

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

which such disclosures may occur. 

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 Temporary Total Disability Deferment Request asks for information about the borrower’s 

medical condition, and the Economic Hardship Deferment Request asks for income information. 

This information may be considered sensitive by some individuals, but it is needed to establish 

the borrower’s eligibility for the deferment. The deferment forms do not otherwise request any 

sensitive information. 

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.

Estimated annual number of respondents: 3,159,132
7

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

Number of responses per borrower: x 1

Hours per response: x 0.33 hours (20 minutes)

1,042,514 hours

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

There are no capital/startup costs to respondents, nor are there any annual costs to respondents 

associated with operating or maintaining systems or purchasing services.

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.
8

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

There is no significant annualized cost to the Federal government. For the Direct Loan Program, 

the government’s contracts with its Direct Loan servicers is not based on a fee-for-service model; 

rather, the Department pays its servicers based on performance metrics. For the FFEL Program, 

there is no significant cost associated with this collection, since FFEL Program loan holders 

distribute the forms, collect the information, and process the requests. The government incurs no 

additional cost merely as a result of this information collection.

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 reported increase in burden associated with 1845-0102 is caused by two factors. The 

number of respondents is increasing for two reasons: (1) 1845-0102 is being combined with 

1845-0014, to the extent that 1845-0014 contained information regarding the Income-Based and 

Income-Contingent Repayment Plans for the William D. Ford Federal Direct Loan (Direct Loan) 

Program and 1845-0016 and (2) an adjustment to account for a greater interest in both repayment 

plans and the expansion of the Direct Loan Program.

Through the combing of multiple forms and streamlining, the Department estimates that the 

amount of time necessary per respondent to complete the revised from has decreased from 1.33 

hours to 0.33 hours. Therefore, though the number of respondents increasing is a natural 

consequence of combining multiple forms into one, there is a significant reduction in overall 

burden to respondents, which is masked by the increased population of respondents.

For example, if the Department was not combing 1845-0014 and 1845-0016 with 1845-0102, but 

the time per response was still reduced, there would be a reduction in burden hours of 705,540. 

Similarly, if the Department was combining 1845-0014 and 1845-0016 with 1845-0102, but 

there was no reduction in response time, there would be an increase in burden of 811,333 caused 

solely by the increase reporting population. However, because the Department is both 

combining multiple collections and streaming them, there is only an overall increase in burden of 

105,793.

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.
9

EDICS Tracking and OMB Number: (04906) 1845-0102 Revised: 10/19/2012

RIN Number: N/A (if applicable)

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.