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OMB Number: 1845-0011 Revised: 3/9/2015

RIN Number: N/A

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.

The Higher Education Act of 1965, as amended (the HEA) established the William D. 

Ford Federal Direct Loan (Direct Loan) Program under Title IV, Part D and the Federal 

Family Education Loan (FFEL) Program under Title IV, Part D. Section 455(a)(1) of the 

HEA provides that unless otherwise specified, Direct Loan Program loans are subject to 

the same terms and conditions as loans made under the Federal Family Education Loan 

(FFEL) Program. Sections 428(b)(1)(M) and 428B(d)(1) of the HEA provide that FFEL 

Program borrowers who meet certain eligibility requirements may temporarily defer 

(postpone) repayment of their loans. In accordance with §455(a)(1), these same 

deferment options are available to Direct Loan Program borrowers.

With the exception of in-school deferments (see Item 3 below), the Direct Loan Program 

regulations at 34 CFR 685.204 require a borrower to request a deferment from the U.S. 

Department of Education (the Department) and, in most cases, to provide additional 

information or a certification from a third party that establishes the borrower’s eligibility

for the deferment. 

This collection includes seven separate deferment request forms that serve as the means 

by which a borrower requests a deferment and provides the necessary information and/or 

certifications to establish his or her eligibility for the deferment. The eight deferment 

request forms are:

1. Temporary Total Disability Deferment Request (used by borrowers to request a 

deferment while they are temporarily totally disabled or caring for a spouse or dependent 

who is disabled)

2. In-School Deferment Request (used by borrowers to request a deferment while they are 

enrolled at least half time at an eligible institution, and by certain parent Direct PLUS 

Loan borrowers to request a deferment while the student for whom they obtained a Direct 

PLUS Loan is enrolled at least half time) 

3. Education Related Deferment Request (used by borrowers to request a deferment while 

they are engaged in a graduate fellowship program, rehabilitation training program, or 

 

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OMB Number: 1845-0011 Revised: 3/9/2015

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internship/residency program, and also by certain parent Direct PLUS Loan borrowers to 

request a deferment based on a dependent student’s enrollment in school or participation 

in a rehabilitation training program)

4. Parental Leave/Working Mother Deferment Request (used by borrowers to request a 

deferment while they are on parental leave or are working mothers)

5. Economic Hardship Deferment Request (used by borrowers to request a deferment while 

they are experiencing an economic hardship)

6. Public Service Deferment Request (used by borrowers to request a deferment while they

are performing certain types of public service)

7. Unemployment Deferment Request (used by borrowers to request a deferment while they

are seeking but unable to find employment)

8. PLUS Deferment Request (used by PLUS borrowers to request a deferment while the 

student on whose behalf the parent borrowed is in-school or enrolled in a rehabilitation 

training program)

NOTE: Some of the deferments listed above are available only to borrowers who, at the 

time they received their first Direct Loan Program loan, had an outstanding balance on a 

FFEL Program loan that was made before July 1, 1993. This restriction is explained on 

the applicable deferment request forms included with this submission.

The Department is requesting a revision of the currently approved collection. We are 

simplifying and streamlining the forms such that they are easier for borrowers to 

complete.

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 deferment request forms are used by borrowers to request 

deferments on their loans, and they also collect the information that is required for the 

loan holder to determine whether the borrower meets the eligibility requirements for the 

requested deferment. 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 of information does not involve the use of technological processes such as 

electronic submission of requests. Except for certain borrowers requesting 

unemployment deferments who may qualify for the deferment based on a selfcertification that they have registered with an employment agency, borrowers must either 

submit supporting documentation to establish their eligibility for a deferment or have a 

third party (such as a school official) certify their eligibility for the deferment. As a 
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OMB Number: 1845-0011 Revised: 3/9/2015

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result, electronic submission of most deferment requests is not feasible at this time. 

Although in most cases a borrower must submit a deferment request with the appropriate

documentation to the loan holder, the loan holder may grant an in-school deferment 

without a request from the borrower based on information that the loan holder obtains 

from other sources confirming that the borrower is enrolled at least half time at an 

eligible institution. This reduces burden on borrowers. In such cases, the loan holder

notifies the borrower that the deferment has been granted and provides the borrower with 

the option of canceling the deferment and continuing to make payments on his or her 

loan.

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.

With the exception of the in-school deferment (see Item 3), there is no information 

already available from other sources that can be used to establish a borrower’s eligibility

for a deferment. 

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.

The frequency with which a borrower must request a deferment is determined in 

accordance with statutory and regulatory requirements that are explained on each 

deferment request form. Less frequent data collection would not allow loan holders to 

process borrower requests for deferment. 

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;
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OMB Number: 1845-0011 Revised: 3/9/2015

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 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 above conditions.

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 Department considered comments from the public when developing the currently 

approved forms. Furthermore, the Department will consider any comments provided 

during both the 60-day comment period and the 30-day comment period. This is the 

request for the 60 day public comment period.

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 have been 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 
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OMB Number: 1845-0011 Revised: 3/9/2015

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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 forms include a Privacy Act Notice that (1) informs borrowers of the statutory

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

is voluntary, but is required in order to qualify for a loan discharge; and (3) identifies the 

third parties to whom the information may be disclosed and explains the circumstances 

under which those 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.

 

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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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OMB Number: 1845-0011 Revised: 3/9/2015

RIN Number: N/A

 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.

The previous filing included mathematical errors in the total number of respondents and 

the total number of hours:

Form Respondents/

Responses

Hours/response Previous Total Corrected 

Total

HRD 781,184 .16 125,469.44 124,989

EDU 15,018 .16 2,402.00 2,403

SCH 2,097,910 .16 335,665.60 335,666

PLWM 204 .16 32.64 33

PUB 12,558 .16 2009.28 2,009

TDIS 1,061 .16 169.76 170

UNEM 199,193 .16 3,312.64 31,871

PLUS 20,704 .16 3,312.64 3,313

TOTALS 3,130,831

3,127,832

500,933.00 500,453

Using these corrected numbers as a revised starting point, the information below shows 

the Department’s estimates of the total annual number of respondents, responses and 

burden hours for this information collection.

Economic Hardship Deferment Request (HRD)

Estimated annual number of respondents: 781,184

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 124,989

Education Related Deferment Request (EDU)

Estimated annual number of respondents: 15,018

Number of responses per respondent: x 1
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OMB Number: 1845-0011 Revised: 3/9/2015

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Hours per response: x 0.16

Annual hour burden: 2,403

In-School Deferment Request (SCH)

Estimated annual number of respondents: 2,097,910

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 335,666

Parental Leave/Working Mother Deferment Request

(PLWM)

Estimated annual number of respondents: 204

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 33

Public Service Deferment Request (PUB)

Estimated annual number of respondents: 12,558 

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 2,009

Temporary Total Disability Deferment Request (TDIS)

Estimated annual number of respondents: 1,061

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 170

Unemployment Deferment Request (UNEM)

Estimated annual number of respondents: 199,193

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 31,871

PLUS Deferment Request (PLUS)

Estimated annual number of respondents: 20,704

Number of responses per respondent: x 1

Hours per response: x 0.16

Annual hour burden: 3,313
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OMB Number: 1845-0011 Revised: 3/9/2015

RIN Number: N/A

The Department estimates the total annual number of respondents for this collection to be 

3,127,832. The estimated response time for each of the eight deferment forms is 0.16 

hours (10 minutes), with one response per respondent. This equates to a total estimated 

reporting burden of 500,453 hours.

There are no annual costs to respondents associated with operating or maintaining 

systems or purchasing services.

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 : $0.00

Total Annual Costs (O&M) : $0.00

____________________

Total Annualized Costs Requested : $0.00

There are no capital/startup costs to respondents.

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 
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OMB Number: 1845-0011 Revised: 3/9/2015

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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.

There is no significant cost to the federal government related to these forms from FFEL 

Program, Direct Loan, or Perkins Loan borrowers, since loan holders and servicers

distribute and process the loan discharge applications, and ED servicers do not 

specifically charge the government for distributing these forms.

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 request for a revision of the current information collection 1845-0011. There is 

a minor change to the burden hours and respondents/responses due to mathematical errors 

in the previous filings totals. There are no changes to the information collected on these 

forms however, the forms have been simplified and reformatted to present a common 

layout for these types of requests. There has been no change in the underlying statute or 

regulations which support these request forms. 

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 information collection 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".