### 1

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  Notice : Recommendations by the Office of the General Counsel and the Office of the Inspector General resulted in changing references from “Food Stamps” to Supplemental Nutrition Assistance Program (SNAP) and making the certification statements consistent in the FAFSA and SAR. The changes were intended to provide clarification and do not affect burden in any way. **A. Justific ation**  **1. Explain the circumstances that m ak** **e the collection of inform ation necessary. Identify any legal or**  **administrative requirements that necessitate the collection. Attach a hard**  **copy of the appropriate section of each statute and regulation manda**  **ting or authorizing the collection of inform ation**  **, or**  **you m ay**  **provide a valid**  **URL link or paste the applicable section**  **1 . Specify the review type of the collection (new, revision,**  **extension, reinstatement with change, reinstatem ent without change)**  **. If revis ed, briefly specify the changes.**  **If a rulem aking is involved, make note of the sections or changed sections, if applicable.**  Public Law 89 - 329, Sections 401 - 495, the Higher Education Act of 1965, as amended (HEA), mandates that the Secretary of Education “... shall produce, distribute, and process free of charge common financial reporting forms as described in this subsection to be used for application and reapplication to determine the need and eligibility of a student for financial assistance. .. ” . The determination of need and eligibility are for the following Title IV, HEA, federal student financial assistance programs: the Federal Pell Grant Program; the Campus - Based programs (Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Wo rk - Study (FWS), and the Federal Perkins Loan Program); the William D. Ford Federal Direct Loan Program; the Teacher Education Assistance for College and Higher Education (TEACH) Grant ; and the Iraq and Afghanistan Service Grant. Federal Student Aid, an of fice of the U.S. Department of Education (hereafter “the Department”), subsequently developed an application process to collect and process the data necessary to determine a student’s eligibility to receive Title IV, HEA program assistance. The applicatio n process involves an applicant’s submission of the Free Application for Federal Student Aid (FAFSA). After submission and processing of the FAFSA, an applicant receives a Student Aid Report (SAR), which is a summary of the processed data they submitted o n the FAFSA. The applicant reviews the SAR, and, if necessary, will make corrections or updates to their submitted FAFSA data . The specific questions that applicants are asked to answer in the application process are described separately in the Data Ele ments Justification document. The document lists all the data elements and explains the purpose and use of each in the application. In addition to calculation of financial need for the various Title IV programs, the FAFSA also collects data that allows f or a determination of a student’s eligibility for state and school financial aid programs. If these data elements were not collected, the Department would be unable to make a determination of financial need and subsequently would be unable to award any Ti tle IV, HEA program assistance, as mandated by the HEA. A majority of states would also be greatly hindered in their calculation of state aid to students . **2. Indicate how, by whom , and for what purpose the inform**  **ation is to be used. Except for a new collection,**  **indicate the actual use the agency has m ade of the information received from** **the current collection.** The purpose of the application is to collect personal and financial data from current or prospective students in order to perform a need analysis as described in Part F of the HEA. The application is available in both English and Spanish and the main options for completing a FAFSA include (more specific application options are described in Question 12):

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

### 2

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012 1) FAFSA on the Web (FOTW) submissions – Applicants can complete the online version of the FAFSA which offers a customized experience; 2) Financial Aid Administrator submissions – On behalf of the applicant, this option describes the electronic submission of a FAFSA by a designated third party ( e.g., the Department’s FAA Access system or a postsecondary institution’s mainframe computer); 3) Paper submissions – Applicants can complete and submit the paper version or the PDF version of the FAFSA; these versions must be mailed to the Department for pr ocessing; or As required by Section 483 of the HEA, for students that have previously submitted a FAFSA, there is a Renewal FAFSA that retains certain static data and the applicant only needs to update information that has changed since the previous FAFSA submission. The Renewal FAFSA is offered within FOTW and to applicants who submit with the assistance of a financial aid administrator. The information an applicant is required to provide on the FAFSA varies based upon the need analysis formula that is being utilized. There are three need analysis formulas, the first is for dependent students (this formula also requires parental data), the second is for independent students without dependents other than a spouse, and the third formula is for independent students with dependents other than a spouse. After the application is completed, the student submits the form to the Department and the data is processed by the Department’s Central Processing System (CPS). The need analysis results in an expected fam ily contribution (EFC), which is an index used by postsecondary educational institutions when determining the types and amounts of both federal and non - federal financial aid students will receive. The EFC is calculated in accordance with the statutory for mula in Part F of the HEA and is intended to indicate a student’s ability (and for dependent applicants, his or her family's ability) to contribute toward the student's cost of attending a postsecondary educational institution. The following components ar e considered in the need analysis formula to determine the EFC: 1) The available income of (A) the independent student and (if married) the independent student's spouse, or (B) the dependent student and the dependent student's parents; 2) The number of depend ents in the family of the student; 3) The number of dependents in the family of the student (excluding the parents) who are enrolled or accepted for enrollment, on at least a half - time basis, in a degree, certificate, or other program leading to a recognized educational credential at an institution of higher education that is an eligible institution in accordance with the provisions of Section 102 of the HEA and for whom the family may reasonably be expected to contribute to their postsecondary education; 4) The net assets of (A) the independent student and (if married) the independent student’s spouse, or (B) the dependent student and the dependent student's parents; 5) The marital status of the student; 6) The age of the older parent, in the case of a dependent studen t; and 7) Any additional expenses incurred (A) in the case of a dependent student, when both parents of the student are employed or when the family is headed by a single parent who is employed, or (B) in the case of an independent student, when the student i s married and the student's spouse is employed or when the employed student qualifies as a surviving spouse or as a head of household under Title 26, Subtitle A, Chapter 1, Subchapter A, Part I, Section 2 of the Internal Revenue Code of 1986. The need ana lysis formula used to determine an EFC change s in order to simplify the application for families who meet specific conditions. The HEA specifies a Simplified Needs Test (SNT) for calculating the EFC for families who meet the requirements of Section 479 of the HEA . The SNT applies to families who have adjusted gross incomes less than $50,000 per year, and who meet at least one of the following eligibility requirements: 1) As defined in Section 479(b)(1) of the HEA, have filed or are eligible to file a form 1040A or 1040EZ; or 2) The independent student, independent student’s spouse, or the dependent student's parent(s) received benefits in the last 24 months from any of the following federal means - tested benefit programs: Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) ( formerly the Food Stamp Program ) , Free or Reduced Price Lunch, Temporary Assistance for Needy Families (TANF), and Special Supplemental Nutrition Program for Women, Infants, and Children (WIC); or 3) The indep endent student, independent student’s spouse, or the dependent student's parent(s) is a dislocated worker. All assets are excluded from consideration when calculating the EFC for families who meet the SNT requirements resulting in a Simplified Needs Analysis that utilizes the following six components:

### 3

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012 1) Adjusted gross income; 2) Federal taxes paid; 3) Untaxed income and benefits; 4) The number of family members; 5) The number of family members (excluding the parents) in postsecondary education; and 6) An allowance ( A) for federal and other taxes, as defined in Section 475(c)(2) of the HEA for parents and dependent students and in Section 477(b)(2) of the HEA for independent students with dependents, or (B) for federal and local income taxes, as defined in Section 476 (b)(2) of the HEA for independent students without dependents. In addition to the Simplified Needs Analysis, there is another circumstance where the need analysis formula to determine an EFC is modified. Section 479(c) of the HEA further simplifies the a pplication by establishing an Automatic Zero (Auto Zero) formula permitting the automatic determination of an EFC of zero for families within a certain income threshold, and who file or are eligible to file the Internal Revenue Service (IRS) forms 1040A or 1040EZ or who received benefits from one of the federal means - tested benefit programs described above, or for those who meet the dislocated worker criteria. The College Cost Reduction and Access Act of 2007 (P.L. 110 - 84) indexed the income threshold to b e updated annually according to increases in the Consumer Price Index (CPI). For the 2013 - 2014 application cycle the income threshold will be $ 24 ,000 for the Auto Zero formula. The Auto Zero formula excludes other income and all assets for the purpose of calculating an EFC. Independent students with no dependents other than a spouse are not eligible to receive an automatic zero EFC determination. Once the CPS processes the applicant’s data using the appropriate need analysis formula, the Department send s an Institutional Student Information Record (ISIR) electronically to the postsecondary institutions the applicant listed on the FAFSA . An ISIR is also sent to the S tate grant agencies (based on the applicant’s state of legal residence), as well as the s tates where the institutions the applicant listed on his or her FAFSA are located. The Department notifies the applicant by sending a Student Aid Report (SAR) in the language the applicant used to submit the FAFSA. Similar to the ISIR, the SAR will conta in the results of the processed application, including the student’s EFC, a transcript of the information that the student originally reported on the FAFSA, and other relevant information (e.g., the applicant’s financial aid history from the Department’s N ational Student Loan Data System (NSLDS)). There are three versions of the SAR that an applicant may receive; a paper SAR, a paper SAR Acknowledgment, or an eSAR. 1) The paper SAR is a full summary that is mailed to applicants who filed a paper FAFSA and w ho did not provide an e - mail address. A paper SAR is also mailed to applicants whose records were rejected due to critical errors during processing . 2) The SAR Acknowledgment is a condensed paper SAR that is mailed to applicants who applied electronically , b ut did not provide an e - mail address and do not meet the criteria for a full SAR. 3) The eSAR is an online version of the SAR that is available on FOTW to all applicants with a PIN . Notifications for the eSAR are sent to students who applied electronically or by paper and provided an e mail address. These notifications are sent by e - mail and include a secure hyperlink that takes the user to the FOTW site. Applicants are expected to review the information on their SAR and, if necessary, correct errors in t he reported information, verify the responses if so requested, and supply any missing information. Specifically, there are several ways that an applicant can correct, update or provide additional information: 1) FOTW – Any applicant who has a Federal Student Aid PIN (FSA PIN) – regardless of how they originally applied – may correct any of the data on the FAFSA, except t he applicant’s Social Security N umber (SSN), by using the corrections functionality on the FOTW sit e. 2) Paper SAR – Applicants who receive or request a paper SAR can make hand - written corrections or additions directly on the paper SAR and mail it back to the Department. Corrections to the applicant’s SSN can be made using the paper SAR. Note that althou gh the paper SAR can be used to make changes, the SAR Acknowledgment and the eSAR cannot be used for corrections. 3) FAA Access - With the applicant’s permission, an institution can use FAA Access to correct the FAFSA. 4) Electronic Other – With the applicant’s permission, corrections can be made via the postsecondary institution’s third - party servicer, a postsecondary institution’s mainframe computer, or a postsecondary institution’s proprietary software for the student.

### 4

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012 5) Federal Student Aid Information Center ( FSAIC) – FSAIC has the ability to assist applicants with a limited amount of changes. Any applicant, who has their Data Release Number (DRN), can make changes to the postsecondary institutions listed on their FAFSA or change their address by calling FSAIC . An applicant who corrects and/or updates (as defined in 34 CFR 668.55) their FAFSA resubmits the information to the Department. The Department, in turn, processes the changed information and sends the applicant a revised SAR. For most applicants the a pplication process is now concluded, as the Department has processed the most accurate and complete information for use in the need analysis formula and the postsecondary institution is able to determine eligibility and award aid. Regulations, however, es tablished a verification process (as defined in 34 CFR 668, Subpart E) that require s some applicants to provide documentation to the postsecondary institution to confirm the information reported on the FAFSA. These procedures “...govern[s] the verification by institutions of information submitted by applicants for student financial assis tance in connection with the calculation of their expected family contributions (EFC).” Applications are selected for verification either by the CPS or by the postsecondary institution. A postsecondary institution must verify all applications the CPS se lects for verification. For students selected for verification, they must complete the verification process with the postsecondary institution, and then the postsecondary institution can award aid once any final changes are submitted to the CPS for proces sing. In conclusion, the above narrative provides an overview of the application process that exists to determine an applicant’s eligibility for Title IV, HEA program assistance . Since Title IV, HEA funds should only be awarded to eligible students and the amounts awarded should reflect the actual need of the applicant and family, the awarding of aid by the financial aid office at the postsecondary institution does not occur until the applicant has completed the entire application process – initial submi ssion, review, corrections and/or verification, if necessary. The entire application process allows the Department to capture the most complete and accurate information for use in the need analysis formula and reduces the possibility that an applicant cou ld receive Title IV, HEA funds they are not eligible to receive. **3. Describe whether, and to what extent, the collection of inform ation involves the use of autom**  **ated, electronic, m** **echanical, or other technological collection techniques or forms of inform ation 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.**  Over time, the Department has made seve ral process improvements that have utilized technology advancements. The following describes some components of the application process that have incorporated such advancements. **FAFSA on the Web** Section 483(a)(3) of the HEA mandates that, “The Secretary shall produce, distribute, and process forms in electronic format...”. Subsequently, the Department developed FOTW in 1998. FOTW has grown to be the primary entry point for tens of millions of students who apply for F ederal, S tate and institutional financi al aid. The Department endeavors to improve FOTW continually to further simplify the application experience for students and families. The following describes the benefits of using FOTW :
 Applications submitted through FOTW are processed much faster than the paper or PDF versions of the FAFSA.  Applicants that have previously applied for aid benefit by completing the Renewal FAFSA, which retains certain static data. Of the static data elements, o nly information that has changed since the previous FAFS A submission needs to be updated and the new data added .  Applicants that need to correct or provide missing information can do so easily by returning to FOTW.  FOTW offers skip - logic and assumption - logic that creates a customized, smart application experien ce based on an applicant’s personal data and previous answers.  Applicants who use FOTW benefit from web edits that ensure all required fields are completed and all data conflicts are resolved prior to application submission, which makes for a reduced appli cation rejection rate duri ng processing. (Approximately 13% of paper FAFSAs and 3% of electronic FAFSAs are rejected due to errors or other anomalies. These percenta ges are for non - signature rejects only.)  FOTW is a safe and secure Web site that uses standard commercial encryption protocols that determine the highest encryption level the browser will support.

### 5

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

 In compliance with the Americans with Disabilities Act, FOTW is 508 compliant and accessible to v isually impaired applicants. In addition to the stated benefits of using FOTW, improvements made in January 2011 demonstrate a continued commitment by the Department to identify opportunities that will assist applicants in the process. In conjunction wit h a technology upgrade , the application site deployed new features including a redesigned homepage and more dynamic and personalized navigation. In addition, simplified functionality for users that need to correct or update their FAFSA data using FAFSA Co rrections was implemented. FOTW also expanded the offering of the IRS Data Retrieval T ool to more users by offer ing the T ool earlier in the appl ication cycle and offering the T ool in FAFSA Corrections. The Tool significantly simplifies the completion of the FAFSA for many applicants by allowing the applicant and their parents, if parental information is required, to access and transfer directly from the Internal Revenue Service (IRS) the IRS tax information requir ed to complete the FAFSA. The T ool saves time and increases the accuracy of the data submitted. In January 2012, further enhancements were made to FOTW and the Tool to continue to simplify the user experience. System logic th at determines to whom the T ool should display was improved so that app licants and their parents are encouraged to use the Tool when eligible, but not offe red the Tool otherwise. The Tool display logic is based on the likelihood that complete and accurate tax data is available to the applicant . For example, the new logic do es not enable the Tool for a married applicant filing separately or for an applicant who filed an amended tax return since this information would not be adeq uate to calculate an accurate EFC. The Tool also helps to maximize the re - use of information that has already been collected from the public by the IRS. As discussed later in #15, t he estimated time an applicant spends preparing, completing and submitting the application for 2013 - 2014 is projected to decrease . T he Tool saves preparation and completion time and also increases the accuracy of the data submitted. Messaging was also added to FOTW to explain the intent of the legal guardianship question to applicants who indicate they are or were in a legal guardianship situation. Additionally, in an effort to expedite the application process, a more robust federal school code search and selection capability was implemented in 2012. Similar enhancements were also extended to the high school search function. **FSA PIN** The FSA PIN is a 4 - digit num ber used in combinati on with a SSN , name, and date of birth for authentication and identification purposes, and allows access to an individual’s personal information on Department Web sites, such as FOTW. Students and parents can each apply for their own FSA PIN. The FSA PIN can also be used as an electronic signature. Since the submission of the FAFSA requires the applicant’s signature and the parent’s signature if the applicant is a dependent student and parental information is provided, the FSA PIN fa cilitates an easier application experience, eliminating the need for a paper signature submission. In addition, the FSA PIN can be used each year to access the Renewal FAFSA and to access FAFSA data and make corrections or updates. **Custo mer Service**  **– FSA**  **IC** In addition to the assistance provided by FSAIC when handling inquiries about the financial aid process and questions about the application, FSAIC offers technological features that have simplified the application experience for many applicants.

 FAFSA on the Phone (FOTP) – FSAIC began offering FOTP as an alternative to filing the FAFSA using FOTW or mailing in a paper FAFSA. Students and families can simply call FSAIC and file by phone. Th is option is intended for applicants who have limited or no Int ernet access and who may be facing pressing deadlines. Although it is not a widely utilized service, it provides a valuable service to students who need the personalized assistance.

 Live Help – Live Help is a secure online chat session where applicant questions are answered. FSAIC reported 1.46 million Live Help inquiries in 2011. Given the steady growth of this form of communication, the Department conducted a usability study of FSAIC’s Live Help capabil ity to evaluate customer usage and identify areas for future improvement. Based on the results of that study, t he W eb chat capability was substantially upgraded in 2012. These changes should facilitate use of this inquiry channel and improve the applicant experience. **Image an d Data Capture (IDC)** 

### 6

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012 The Department has maintai ned the IDC document management system. The system scans images, captures data, and sends the data for processing to the CPS. The IDC utilizes optical character recognition (OCR) to electronically recognize and capture typed or hand - written data from the paper FAFSA, PDF FAFSA and SAR. Use of this technology results in the automation of data entry tasks, thus reducing the processing time for applicants. **4. Describe efforts to identify duplication. Show s pecifically why any sim** **ilar information already available cannot be used or m** **odified for use for the purposes described in Ite m**  **2 above.** The FAFSA collection requirements do not contain any duplication of data elements. Because legislation requires that the FAFSA be completed annually by applicants, returning applicants encounter similar questions in subsequent years. To reduce that burden, the Renewal FAFSA is available and reuses much of the data previously submitted. Required responses on the Renewal FAFSA are limited to income and asset questions likely to change from year to year. The review and corrections segment of the application process does not duplicate the process of initial data collection . Reviewing and correcting the application is also fundamental to the application experience because it creates an opportunity to obtain the most accurate applicant information. **5. If the collection of information im pacts small businesses or other sm**  **all entities, describe any m ethods used**  **to m ini**  **mize b urden. A sm**  **all entity m ay be (1) a sm**  **all business which is dee med to be one that is**  **independently owned and operated and that is not dom inant in its field of operation; (2) a sm**  **all organization that is any not** **- for** **- profit enterprise that is independently ow**  **ned and operated and is not dom inant in its field;**  **or (3) a sm all governm** **ent 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 eligibility i nformation for the awarding of student aid does not impact small businesses. **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 obsta cles to reducing burden.**  If the application process was not completed and data elements not collected, the Department would be unable to make an accurate determination of financial need and subsequently award any Title IV, HEA program assistance, as mandated . In addition, the HEA requires annual determination of the applicant’s need for Title IV, HEA program assistance. If the data were collected less frequently, the Department would be in violation of the law. A lthough an a pplicant must reapply and receive a new need analysis for every year that student aid is requested, use of the Renewal FAFSA, as described previously, reduces the amount of new data that a student must provide. As a part of the annual application proces s, the corrections component provides an opportunity for the applicant to make corrections. The corrections component is crucial in assuring that comprehensive, accurate data is used to calculate the applicant’s EFC and overall financial aid eligibility. If the Department were unable to request verification or correction of submitted data, the EFC could be calculated using questionable or erroneous data. In addition, errors discovered as a result of multiple federal database matches (e.g., SSA, Departmen t of Homeland Security (DHS), Veteran Affairs, etc.) could not be corrected. The result would be countless incomplete or inaccurate FAFSA applications and, potentially, millions of incorrect eligibility determinations resulting in the loss of taxpayer dol lars by awarding Title IV , HEA program assistance based on erroneous applicant data. **7. Explain any special circumstances that would cause an inform ation collection to be conducted in a m**  **anner:**  **requiring respondents to report inform ation to the agency m** **or e often than quarterly;**   **requiring respondents to prepare a written response to a collection of inform ation in fewer than 30**  **days after receipt of it;**  **requiring respondents to submit more than an original and two copies of any document;**  **requiring respondent s to retain records, other than health, m**  **edical, governm ent contract, grant** **- in**  **** **aid, or tax records for m ore 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 OM**  **B;**

### 7

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

 **that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not suppor** **ted 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 conf idential inform**  **ation unless the agency can dem** **onstrate that it has instituted procedures to protect the inform ation’s**  **confidentiality to the extent permitted by law.** The application does not invoke special circumstances, as described in the Paperwork Redu ction Act submission instructions. **8. As**  **applicable, state that the Departm** **ent has published the 60 and 30 Federal Register notices as required**  **by 5 CFR 1320.8(d), soliciting comments on the inform ation collection prior to submission to OMB.**  **Summarize publi c 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 t**  **heir views on the availability of data, frequency of collection, the clarity of instruction and record keeping, disclosure, or reporting**  **form at (if any), and on the data elem** **ents to be recorded, disclosed, or reported. Consultation with representatives of**  **those from whom** **inform ation is to be obtained or those who m** **ust com** **pile records should occur at least once every 3 years**

**– even if the collection of inform**  **ation activity is the sam** **e as in prior periods. There may be circumstances that m ay preclude consul** **tation in a specific situation. These circumstances should be explained.**  The Department published the 60 - day Federal Register notice inviting public comment s in Vol. 77, page 48970, on August 15, 2012. We received comments from 23 individuals or organiz ations and have addressed them in a separate document entitled FSA Application Comments Tracking Summary. **9. Explain any decision to provide any paym**  **ent or gift to respondents, other than remuneration of contractors or grantees**  **with m eaningful justificati**  **on .**  There are no payments or gifts for the completion and/or submission of the application. **10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally iden**  **tifiable inform ation (PII) is being collected, a Privacy**  **Act statem ent 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 statem ent with a legal citation that authorizes the**  **pledge of**  **confidentiality should be**  **provided. 2**  **If the collection is subject to the Privacy Act, the Privacy Act statem ent is deemed sufficient with**  **respect to confidentiality. If there is no expectation of confidentiality, simply state that the Departm**  **ent make s**  **no pledge about the confidentially of the data.** The confidentiality of the data collected is discussed in the Routine Uses section of the System of Records Notice for the Federal Student Aid Application File (18 - 11 - 01), published in 64 FR 30159 – 30161 (June 4, 1999), as corrected by, 64 FR 72407 (December 27, 1999), as corrected by, 65 FR 11294 (March 2, 2000), as corrected by 66 FR 18758 (April 11, 2001), and as corrected by, 74 F R 68802 - 68808 (December 29, 2009).

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)

### 8

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012 A section on privacy, printed on page 10 of the paper FAFSA and linked from the homepage of FOTW, informs the student that postsecondary educational institutions and S tate financial aid agencies to which the student requ ests his or her data be sent will have access to the data, and that the grant agencies in the applicant’s state of legal residence will receive certain information even if the student does not provide consent pursuant to section 483(a) of the HEA. Privacy Act information is repeated on the paper SAR and accessible at all times from FOTW. In addition, agencies such as law enforcement agencies, the Office of Management and Budget (OMB), the Department of Justice (DOJ), the Government Accountability Office ( GAO), Congress, and other entities have access to the data. No other individuals have access to this information without the express written consent of the applicant. **11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and**  **attitudes, religious beliefs, and other m atters that are commonly considered private. The justification should**  **include the reasons why the agency considers the questions necessary, the specific uses to be m ade of the**  **inform ation, the**  **explanation to be given to persons from whom** **the inform ation is requested, and any steps to**  **be taken to obtain their consent.** Except for question 23 (have you been convicted for the possession or sale of illegal drugs for an offense that occurred while yo u were receiving federal student aid) and questions 24 and 25 (what is your parents’ level of education), the FAFSA does not contain questions of a sensitive nature beyond those needed to obtain the information necessary to complete the need analysis and c alculate an EFC. Question 23 is used to determine a student’s eligibility for Title IV assistance in accordance with section 484(r) of the HEA. Questions 24 and 25 are often used to determine whether an applicant is a first - generation college student a nd may be used by S tate grant agencies, scholarship programs, institutions, and the TRIO programs, which often give special consideration to first - generation college students. The FAFSA instructions inform applicants that their response to question 23 m ay affect their eligibility for F ederal student aid. Other FAFSA instructions inform applicants that their response to questions 24 and 25 do not affect their eligibility for F ederal student aid. **12. Provide estim**  **ates of the hour burden of the collecti on of inform**  **ation. The statement should:**  **Indicate the number of respondents by affected public type (federal governm ent, individuals or**  **households, private sector**

**– businesses or other for** **- profit, private sector** 

**– not** **- for** **- profit**  **institutions, farms, state , local or tribal governm** **ents), 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 inform**  **ation on which to base hour burden estimates. Consultation with a sam ple (fewer than 10)**  **of potential respondents is desirable. If the hour burden on responde nts is expected to vary**  **widely because of differences in activity, size, or com plexity, show the range of estim**  **ated hour burden, and explain the reasons for the variance. Generally, estim**  **ates should not include burden hours for custom**  **ary and usual busines s practices.**   **If this request for approval covers m ore than one form** **, provide separate hour burden estim ates**  **for each form and aggregate the hour burdens in the**  **ROCIS IC Burden Analysis Table.**  **(The table should at**  **mini mum**  **include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)**   **Provide estim ates of annualized cost to respondents of the hour burdens for collections of**  **inform ation, identifying and using appropriate wage rate categorie**  **s. The cost of contracting out or paying outside parties for inform**  **ation collection activities should not be included here. Instead, this cost should be included in Item 14.**  The estimates included are the result of the Department’s efforts to determine the public’s burden as it relates to the application process for F ederal student aid. The Applicant Burden Model (ABM), measures applicant burden through an assessment of the activities each applicant conducts in conjunction with other applicant character istics and in terms of burden, the average applicant’s experience. Key determinants of the ABM include:

 The total number of applicants that will potentially apply for federal student aid;  How the applicant chooses t o complete and submit the FAFSA ( e.g., by paper or electronically via FOTW ) ;

### 9

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

 How the applicant chooses to submit any corrections and/or updates (e.g., the paper SAR or electronically via FOTW Corrections);  The type of SAR document the applicant receives ( eSAR, SAR acknowledgment, or paper SAR );  The formula applied to determine the applicant’s EFC (full need analysis formula, Simplified Needs Test or Automatic Zero); and  The average amount of time involved in preparing to complete the application. The ABM is largely driven by the number of potential applicants for the application cycle. The total application projection for 2013 - 2014 is based upon two factors - estimates of the total enrollment in all degree - granting institutions and the percentage change in FAFSA sub missions for the last co mpleted or almost completed application cycle . The ABM is also based on the application options available to students and parents. The Department accounts for each application component based on W eb trending tools, survey information, and other Departmen t data sources. The 2013 - 2014 application projections are estimated based on one response per FAFSA submitted. The projections account for two factors, which include college enrollment projections and FAFSA submission rates for the previously completed cycle. The Projections of Education Statistics prepared by the U.S. Department of Education, National Center for Education Statistics (NCES), Integrated Postsecondary Education Data System provides estimates of the total enrollment in all degree - granting institutions, as shown in Table 1. **Table 1.** Enrollment projections for 2013 from NCES Projection s of Education Statistics to 2020 [in thousands] **Year Enrollment Projections**  2011 20,688 2012 20,727 2013 20,948 2014 21,320 2015 21,651 2016 21,968 2017 22,251 2018 22,546 2019 22,821 2020 23,016 In prior years, the enrollment projections used were based on the “high alternative projections” as calculated by NCES. The high alternatives projections were used to account for the difference in the number of students who may apply for aid and the number of students who may actually enroll in college . The high alternative projections were used in conjunction with the percentage change in FAFSA submissions for the last completed application cycle. For 2013 - 2014 , we will modify our approach because NCES no longer provides “high alternative projectio ns” and instead provides a general projection of college enrollment, reflected in the values in Table 1. After a review of prior year projections, the Department will utilize a fixed 15 percent to calculate a “high alternative” for future years, and will use that in conjunction with the percentage change in FAFSA submissions, which for 2011 - 2012 was 4 percent. Based on these factors, the Department estimates that **25,053,80 9**  total applicants will submit a FAFSA for 2013 - 2014; an increase of 347,945 applica nts from the 2012 - 13 projections. Once the applicant volume is projected, we determine overall estimated burden and overall cost by examining each FAFSA completion method. The completion method reflects how applicants choose to complete and submit the FA FSA, and indicates the needs analysis formula the applicant was presented with when they completed the FAFSA. Each completion method is assigned an individual burden estimate to reflect the average time an applicant will spend to complete and submit a FAFSA and/or correction. For 2013 - 2014 estimates, we determined that since the 2011 - 12 cycle offers more complete data set than the 2012 - 13 cycle (17 months versus 5 months), usage data from the 2011 - 2012 application cycle accurately reflects overall usage of each completion method. It should also be note d that the Department determined that recordkeeping would not be documented as a component of the burden estimate. Since the Department retains, for the applicant, summaries of the data submitted and a history of their changes, the need for an applicant to retain a set of records is optional.

### 10

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012
The components that were included in the individual burden est imate include information from W eb trending tools and user perception data from surveys and this allowed us to estimate the individual burden for each completion method. The individual burden estimate includes the following: 1) Preparation – Average time it takes to review instructions and gather the documents necessary to complete the FAFSA (e.g., paper FAFSA, copies of W - 2 Forms, Student/Spouse and/or Parent’s Federal Income Tax Returns, bank statements); 2) Completi on – Average time it takes for data entry (paper or electronic), referencing instructions, or accessing on - line help or calling customer service; 3) Submission – Average time it takes to review the Certification Statement, apply signatures, make copies of pap er forms or print electronic outputs, and if necessary, obtain postage and mail. As a result, Table 2 details the initial submission behavior (completion method) and provides the total burden for submission of the FAFSA; along with associated costs by typ e of application. Table 3 details the corrections behavior by type of corrections submitted and allows us to calculate the burden associated with each correction method; associated costs by type of correction are also provided. It is important to highligh t the decrease of 695,961 corrections projected for the 2013 - 14. Table 4 shows the total number of SARs distributed as a result of the initial submission of the FAFSA and any corrections made. This table also identifies the type of SARs distributed and p rovides associated cost for each . Lastly, Table 5 summarizes the overall total burden and overall total costs for the 2013 - 2014 Federal Student Aid Application. The total estimated burden for the 2013 - 2014 Federal Student Aid Application is **25,9 59,853**  **hours** . Table 5 also summarizes the annual cost burden to complete the application process, which is **$ 190,224.76**  . This cost is attributed to the individual postage cost of 44 cents that would be required of applicants who choose to submit a paper FAFSA (Ta ble 2) or a paper SAR (Table 3). **Table 2.** Initial Submission of FAFSA
**Type of Application Filed Type of**  **FAFSA Applicant**  **(Independent or Dependent)**  **Percent Estimated**  **Number of Applicants**  **(Volume) Estimated** 

**Individual Applicant**  **Burden (Hours)**  **Estimated**

**Individual Applicant Cost**  **(Dollars) Total** 

**Burden for All**  **Applicants (Hours)**  **Total Cost for All**

**Applicants (Dollars)**  **FAFSA on the Web (FOTW) FOTW**  (IC 1) Overall Usage 43.25% The online version of the FAFSA that offers applicants a customized experience. Dependent 40% 4,334,309 1.11 $
- 4,811,083 $
- Independent 60% 6,501,463 0.72 $
- 4,681,05 3 $
- **Subtotals 10,835,772**  **9,492,13 6**  $
- **FOTW -**  **Renewal** (IC 2) Overall Usage 40.75% The online version within FOTW for applicants who have previously completed the FAFSA. Dependent 44% 4,492,148 0.92 $
- 4,132,776 $
- Independent 56% 5,717,279 0.56 $
- 3,201,676 $
- **Subtotals 10,209,427**  **7,334,452** $
- **FOTW -**  **EZ** (IC 3) Overall Usage 6.50% The online version within FOTW for applicants who qualify for the Simplified Needs Test (SNT) or Automatic Zero (Auto Zero) needs analysis formulas. Dependent 31% 504,834 1.03 $
- 519,979 $
- Independent 69% 1,123,664 0.68 $
- 764,09 2 $
- **Subtotals 1,628,498**  **1,284,07 1**  $
- **FOTW -**  **EZ Renewal** (IC 4) Overall Usage 6.10% The online version within FOTW for applicants who have previously completed the FAFSA Dependent 33% 504,333 0.78 $
- 393,380 $
- Independent 67% 1,023,949 0.51 $
- 522,214 $
-

### 11

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

**Type of Application Filed Type of**  **FAFSA Applicant**  **(Independent or Dependent)**  **Percent Estimated**  **Number of Applicants**  **(Volume) Estimated** 

**Individual Applicant**  **Burden (Hours)**  **Estimated**

**Individual Applicant Cost**  **(Dollars) Total** 

**Burden for All**  **Applicants (Hours)**  **Total Cost for All**

**Applicants (Dollars)**  and who qualify for the Simplified Needs Test (SNT) or Automatic Zero (Auto Zero) needs analysis formulas. **Subtotals 1,528,282**  **915,594** $
-
**FOTP -**  **FAFSA on the Phone** (IC 5) Overall Usage 0.008% FSAIC customer service representatives assist applicants by filing the FAFSA on their behalf through FOTW. Dependent 21% 395 0.99 $
- 391 $
- Independent 79% 1,484 0.64 $
- 950 $
- **Subtotals 1,879**  **1,341** $
- **FOTW -**  **FAFSA on the Phone EZ**  (IC 6) Overall Usage 0.003% FSAIC customer service representatives assist applicants by filing the FAFSA on their behalf through FOTW Dependent 26% 163 0.89 $
- 145 $
- Independent 74% 463 0.58 $
- 269 $
- **Subtotals 626**  **414** $
- **School Entry FAA Access**  (IC 7) Overall Usage 1% With the FAFSA filer’s permission, an institution can use FAA Access to submit the FAFSA Dependent 23% 34,574 1.36 $
- 47,021 $
- Independent 77% 115,749 0.97 $
- 112,277 $
- **Subtotals 150,323**  **159,29 8**  $
- **FAA Access -**  **Renewal** (IC 8) Overall Usage 0.40% With the FAFSA filer’s permission, an institution can use FAA Access to submit the Renewal FAFSA for an applicant Dependent 25% 25,054 1.17 $
- 29,313 $
- Independent 75% 75,161 0.81 $
- 60,880 $
- **Subtotals 100,215**  **90,19 3**  $
- **FAA Access -**  **EZ** (IC 9) Overall Usage 0.50% With the FAFSA filer’s permission, an institution can use FAA Access to submit the Renewal FAFSA for an applicant Dependent 34% 42,591 1.28 $
- 54,51 6 $
- Independent 66% 82,678 0.93 $
- 76,89 1 $
- **Subtotals 125,269**  **131,407** $
- **FAA Access -**  **EZ Renewal** (IC 10) Overall Usage 0.25% With the FAFSA filer’s permission, an institution can use FAA Access to submit the Renewal FAFSA for an applicant Dependent 37% 23,175 1.03 $
- 23,870 $
- Independent 63% 39,460 0.76 $
- 29,990 $
- **Subtotals 62,635**  **53,860** $
- **Electronic Other** (IC 11) Overall Usage 1.25% "Electronic Other Original" refers to the submission of FAFSA data using the Electronic Data Exchange (EDE) process. With the FAFSA filer’s permission, a FAFSA can be submitted via : a school’s third party servicer, a school’s mainframe computer, or a school’s proprietary software . Dependent 24% 75,162 1.21 $
- 90,94 6 $
- Independent 76% 238,011 0.87 $
- 20 7,070 $
- **Subtotals 313,173**  **29 8,016**  $
-

**Paper Submissions**

### 12

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

**Type of Application Filed Type of**  **FAFSA Applicant**  **(Independent or Dependent)**  **Percent Estimated**  **Number of Applicants**  **(Volume) Estimated** 

**Individual Applicant**  **Burden (Hours)**  **Estimated**

**Individual Applicant Cost**  **(Dollars) Total** 

**Burden for All**  **Applicants (Hours)**  **Total Cost for All**

**Applicants (Dollars)**  **PDF FAFSA or Paper FAFSA** (IC 12) Overall Usage 0.39% The paper version of the FAFSA printed by the Department and provided for applicants who are unable to access the Internet or the online version of the printed FAFSA for applicants who can access the Internet but are unable to complete the form using FOTW. Dependent 39% 38,107 2.04 $ 0.44 77,738 $ 16,767.08 Independent 61% 59,603 1.71 $ 0.44 101,921 $ 26,225.32 **Subtotals 97,710**  **179,659** $ 42,992.40

**Total Applicants (Responses)**  **25,053,80 9**  **Applicant Burden (Hours) 19,940,441**  **Applicant Cost (Dollars) $42,992.40**  **Table 3.** Correcting Submitted FAFSA Information

**Type of Correction Type of**  **FAFSA Respondent**  **by Filing Option**  **(Independent or**  **Dependent) Percent**  **Estimated Number of**  **Corrections Received**  **(Volume) Estimated** 

**Individual Burden**  **(Hours) Estimated** 

**Individual Applicant Cost**  **(Dollars) Total Burden** 

**for All Respondents**  **(Hours) Total Cost for** 

**All Applicants**  **(Dollars)**

**FOTW -**  **Corrections** (IC 13) Overall Usage 42% Any applicant who has a Federal Student Aid PIN (FSA PIN) – regardless of how they originally applied – may correct using Corrections with FOTW. Dependent 51% 4,504,836 .17 $
- 765,822 $
- Independent 49% 4,390,970 0.1 3 $
- 570,826 $
-

**Electronic Other -**  **Corrections** (IC 14) Overall Usage 29% With the applicant's permission, corrections can be made via: a school’s third party servicer, a school’s mainframe computer, FAA Access or a school’s proprietary software. Dependents & Independents 6,149,407 0.17 $
- 1,045,399 $
-

**Paper SAR** (IC 15) Overall Usage 2% Applicants can write corrections directly on the paper SAR and mail for processing. Dependents & Independents 334,619 0.34 $ 0.44 113,770 $ 147,232.36

**FAA Access** - Corrections (IC 16) Overall Usage 12% With the FAFSA filer’s permission, an institution can use FAA Access to correct the FAFSA. Dependents & Independents 2,470,706 0.17 $
- 420,020 $
-
**Internal Department Corrections**  (IC 17) Overall Usage 14%

### 13

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012

**Type of Correction Type of**  **FAFSA Respondent**  **by Filing Option**  **(Independent or**  **Dependent) Percent**  **Estimated Number of**  **Corrections Received**  **(Volume) Estimated** 

**Individual Burden**  **(Hours) Estimated** 

**Individual Applicant Cost**  **(Dollars) Total Burden** 

**for All Respondents**  **(Hours) Total Cost for** 

**All Applicants**  **(Dollars)**
The Department will submit an applicant's record for system
generated corrections. There is no burden to the applicants under this correction type. Dependents & Independents 2,895,819 0.00 $
- 0 $
-

**FSAIC Corrections** (IC 18) Overall Usage 1% Any applicant, who has their Data Release Number (DRN), can make changes to the postsecondary institutions listed on their FAFSA or change their address by calling FSAIC. Dependents & Independents 298,842 0.05 $
- 14,942 $
-

**Total Corrections (Responses) 21,045,**  **199 Applicant B**  **u rden (Hours)**  **2,930,779 Applicant Cost (Dollars)**  **$147,232.36 Table 4.**  Reviewing FAFSA Information – Student Aid Report Distribution
**Type of SAR Sent Type of FAFSA**  **Respondent by Filing Option**  **(Independent or Dependent)**  **Documents**

**Sent (Volume)**  **Estimated**

**Individual Burden**  **(Hours) Estimated** 

**Individual Applicant**  **Cost (Dollars)**  **Total Burden**

**for All**  **Applicants (Hours)**  **Total Cost**

**for All Applicants**  **(Dollars) SAR Electronic (eSAR)**  (IC 19) Distribution 90% PDF version of the SAR for applicants who applied electronically or by paper and provided an e - mail address. Dependents & Independents 41,489,10 8 0.05 $
- 2,074,455 $
-
**SAR Acknowledgment** (IC 20) Distribution 5% Condensed paper SAR that is mailed to applicants who applied electronically but did not provide an e - mail address. Dependents & Independents 2,304,95 0 0.10 $
- 230,495 $
-
**Paper SAR** (IC 15) Distribution 5% Full paper summary that is mailed to applicants who filed a paper FAFSA and who did not provide an e - mail address and to applicants whose records were rejected due to critical errors during processing . Dependents & Independents 2,304,95 0 0.34 $
- 783,683 $
-

**Total SARs Distributed 46,099,00**  **8 Applicant Burden (Hours)**  **3,088,633 Applicant Cost (Dollars)**  **$0.00**

### 14

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012
**Table 5.** Total Burden and Total Costs for 2013 - 2014 F ederal Student Aid Application **Application Process Responses**  **Burden (Hours) Cost (Dollars)**  Initial Submission 25,053,80 9 19,940,441 $42,992.40 Corrections 21,045, 199 2,930,779 $147,232.36 SAR Review 0 3,088,633 $0.00 **Total Annual Responses 46,099,00**  **8 Total Burden for All Applicants**  **25, 9**  **59 ,853**  **Total Cost for All Applicants $190,224.76**  **13. Provide an estim**  **ate of the total annual cost burden to respondents or record keepers resulting from** **the collection of inform**  **ation. (Do not include the cost of any hour burden shown in Items 12 and 14.)**  **The cost estimate should be split into two com ponents: (a) a total capital and start** **- up cost com** **po nent**  **(annualized over its expected useful life); and (b) a total operation and m aintenance and purchase of**  **services component. The estim ates should take into account costs associated with generating,**  **maintaining, and disclosing or providing the inform atio**  **n. Include descriptions of methods used to estim**  **ate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the tim**  **e period over which costs will be incurred. Capital and start** **- up costs include, am** **ong other item s, preparations for collecting inform**  **ation such as purchasing computers and software; m** **onitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.**   **If cost estim ates are exp**  **ected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out inform**  **ation collection services should be a part of this cost burden estimate. In developing cost burden estim**  **ates, agencies may**  **consult with a sam ple of respondents (fewer than 10), utilize the 60**  **- day pre**  **- OMB submission public**  **comm ent process and use existing economic or regulatory im** **pact analysis associated with the rulemaking containing the inform**  **ation collection, a s 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 inform ation collection, (3) f**  **or reasons other than to provide information or keep records for the**  **governm ent**  **or (4) as part of custom ary and usual business or private practices.**  **Also, these estimates should not include the hourly costs (i.e., the m** **onetization of the hours) captured ab**  **ove in Item 12**  **Total Annualized Capital/Startup Cost :**  **Total Annual Costs (O&M) :** 

**____________________ Total Annualized Costs Requested**  **:** Other than the costs shown in Items 12 and 14, there is no annual cost burden to respondents or record keepers . **14. Provide estim**  **ates of annualized cost to the Federal governm** **ent. 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 wou ld not have been incurred**  **without this collection of inform ation. Agencies also may aggregate cost estim**  **ates from Ite**  **ms 12, 13, and 14 in a single table.**  The projected cost to the federal government to produce, process, and distribute the application and related application products or materials is **$ 79,733,134**  **.** The projections include the costs associated with the Department’s CPS and other costs like printing, mailing and customer service. See the following Table for cost details.

### 15

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012
**Table 6.** Annual Costs **Projected Costs Category 1**  **– Front End Business Integration (FEBI) per Applicant Services:**  This category is the primary delivery area performed under the FEBI contract under the tiered per applicant pricing structure. It consists of system develop ment and maintenance of the FEBI Information Technology (IT) products and the primary operational programs: Central Processing Systems (CPS) mainframe software and systems, develop the paper application and other paper products related to eligibility, stat us reports, ongoing support of existing software and hardware, management of volume peaks, cooperation with multiple contractors, Personal Identification Number (PIN) database, Managing Printing of CPS mailing, Federal Student Aid Information Center (FSAIC ), Editorial Services, CPS/ Student Aid Information Gateway (SAIG) Help desk & Customer Communications, Image and Data Capture (IDC), E - mail, Print, and other Operational Services including Conference Support, Participation Management (PM) Operations, Form Support (FAFSA Forms and PM Enrollment Forms,) and Federal Student Aid Training. **$74,489,804**

**Category 2 -**  **Other FEBI Programs and Products: COD Ancillary Services**  Printing, mailing, imaging, and storing paper promissory notes. **$2,508,314 School Products**  Providing schools with the EDExpress suite of software products to participate in Electronic Data Exchange **$536,225 Postage**  Mailing SARs and SAR Acknowledgments, PIN mailers and PIN reject letters, Renewal Application reminder letters and follow - up letters, subsequent application letters and IRS income follow - up notification letters. **$2,198,791**

**Total Projected Annual Cost**  **$79,733,134 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 o rganic increase in the size of the reporting universe). Program**  **changes result from a**  **deliberate action that m aterially changes a collection of inform**  **ation and generally are result of new statute or an agency action (e.g., changing a form** **, revising regulat ions, redefining the respondent universe, etc.).**  **Burden changes should be disaggregated by type of change (i.e., adjustm ent, program change due to new**  **statute, and/or program change due to agency discretion), type of collection (new, revision, extension,**  **r einstatem** **ent with change, reinstatement without change) and include totals for**  **changes in burden hours ,**  **responses and cost**  **s (if applicable)**  **.** The Department is reporting a net burden reduction of 3,39 8,000 hours, attributed to both a pr ogram change and an adjustment. As stated in Question 3, t he **program change** is the Department’s continued efforts to simplify FOTW, which is utilized by the majority of applicants who apply for aid. Simplification of the application is demonstrated by: 1) the average complet ion times for initial submissions and; 2) fewer corrections being made to the application. The projected average completion time for initial submissions has decreased by 11 minutes for 2013 - 14. In data reported in the 2012 - 2013 supporting statement, first - time filers using FOTW took approximately 1.30 hours (78 minutes) to submit an application. The projected average completion time for 2013 - 2014 is 1.11 hours (67 minutes), reducing burden for initial submissions by 11 minutes . Corrections are also projected to decrease by 695,961 responses for 2013 - 14. Fewer corrections mean that more comprehensive and accurate data was captured in the initial submission of the application. Updated completion times were calcula ted for each component and have been u sed to estimate the burden in Table 7, excluding the change in the applicant volume. The results demonstrate that the burden for all applicants would have decreased by almost - 12.8 percent or 3,75 8 ,702 hours, if the application volume had remained constan t .

### 16

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012
**Table 7.** Applicant Burden Change using 2013 - 2014 Burden Estimates **201 2**  **- 201**  **3 201**  **3 -**  **201 4**  ***** **Change % Change**  **Burden Disposition**

*Accounting only for change in applicant burden; **does not include** change in applicants. Total Applicants 24,705,864 24,705,864 0 0.00% Total Applicant Burden 29 , 357, 853 25, 599,151 - 3,758,702 - 1 2.8 % **Program Change.** The Department’s simplification efforts have caused a decrease in burden. If the Department had not simplified the application process, thus reducing the time required to complete the FAFSA, the new burden estimates would only need to account for the change in applicants. The increase in applicants expected would result in an increase in burden of approximately 360,702 hours. Table 8 reflects the **adjustm ent**  to the overall burden caused by the change in applicants, while excluding the change in applicant burden. **Table 8.** Applicant Burden Change using 2013 - 2014 Applicant Volume **201 2**  **- 201**  **3 201**  **3 -**  **201 4**  ***** **Change % Change**  **Burden Disposition**

*Accounting for change in applicants; **does not include** change in applicant burden. Total Applicants 24,705,864 25,053,809 + 347,945 + 1.41 % Total Applicant Burden 29,357,853 25,9 59,853 - 3,39 8,000 - 11.6 % **Adjustment.** The increase in applicants accounts for an increase in burden. Accounting for both the increase in total applicants and the decrease in individual applicant burden, the net change is an overall decrease of almost 12 percent or 3,39 8,000 hours. Table 9 shows the net burden change and total cost for applicants. The change in total annual responses is also listed in the Table. Total annual responses includ e the original FAFSA submission and corrections.
**Table 9.** Net Burden Change **201 2**  **- 201**  **3 201**  **3 -**  **201 4**  **Change % Change**  **Burden Disposition**

Accounting for change in applicant burden **and** change in applicants. Total Applicants 24,705,864 25,053,80 9 + 347,94 5 + 1.41 % **Net decrease in burden.** The 1.41 % increase in applicants is offset by the results of the simplification changes implemented by the Department. This has resulted in an overall decrease in burden of 11.6 % or 3,3 98,000 hours. Total Applicant Burden 29,357,853 25,959,853 - 3,39 8,000 - 11.6 %
Total Annual Responses 46,447,024 46,099,00 8 - 348,01 6 - . 75 % Cost for All Applicants $234,804.24 $190,224.76 $ 44,579.48 - 18.99 % The Department takes pride in the continued efforts to simplify the FAFSA submi ssion process and the continued decrease in burden associated with the application process, even as the Department serves more students each year. The results confirm the significant improvements that have been made to the application process. The Depart ment believes that these changes will lead to more students completing the FAFSA and will assist more students with their pursuit of postsecondary education.

### 17

EDICS Tracking and OMB Number: (04899) 1845
- 0001 Revised: 06/25/2012
**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 tim** **e schedule for the entire project, including beginning and ending dates of the collection of inform**  **ation, com pletion of report,**  **publication dates, and other acti ons.**  The results of the collected information will not be published for tabulation or publication. **17. If seeking approval to not display the expiration date for OMB approval of the inform**  **ation collection, explain the reasons that display would be**  **inappropriate.** The expiration date for OMB approval will not be included on the 2013 - 2014 paper or PDF FAFSA for design reasons, although the OMB control number is displayed. The term of approval and use of the form is apparent in the first - page instruct ions that inform applicants to send in the form from January 1, 201 3 through June 30, 201 4 . The expiration date for OMB approval will not be included on the 2013 - 2014 paper SAR for design reasons, although the OMB control number is displayed. The term o f approval is apparent in the paper and electronic versions of the application which would have to be submitted in order to generate a SAR . **18. Explain each exception to the certification statem** **ent identified in the Certification of Paperwork Reduction Ac**  **t.** Exceptions to the certification requirement are not requested for this information collection.