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O MB Number: 1845

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**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 c ollection. Attach a hard cop y 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 section 1

. Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y 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 I V, Part D. Section 455(a)(1) of the HEA provides that unless otherwise sp ecified, Direct Loan Program loans are subject to the same terms and conditions as loans made under the Federal Famil y Education L oan (FFEL) Program. Sections 428(b)(1)(M) and 428B(d)(1) of the HEA provide that FFEL Program borrowers who meet certain elig ibility requirements may

temporarily

defer (postpone) repay

ment 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 It em 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 part y 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 o r 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 temporaril y totally disabled or caring for a spouse or dependent who is disabled) 2. In

- School Deferment Request (used b y 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 o btained a Direct PLUS Loan is enrolled at least half time) 3. Education Related Deferment Request (used b y borrowers to request a deferment while they are engaged in a graduate fellowship program, rehabilitation training program, or

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

O MB Number: 1845

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prog ram, and also b y certain parent Direct PLUS L oan 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 b y borrowers to request a deferment while they

are on parental leave or are working mothers) 5. Economic Hardship Deferment Request (used b y borrowers to request a deferment while they are experiencing an economic hardship) 6. Public Service Deferment Request (used b y borrowers to request a deferment while they are performing certain t ypes of public service) 7. Unemploy

ment Deferment Request (used by borrowers to request a deferment while they are seeking but unable to find employ ment) 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 onl y 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 collectio n, 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 ado pting 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 unemploy ment deferments who may qualify for the deferment based on a self

certification that they

have registered with an employ ment agency , borrowers must either submit supporting documentation to establish their eligibility for a de ferment or have a third party

(such as a school official) certify their eligibility

for the deferment. As a3

O MB Number: 1845

- 00 11 Revised: 3/9 /2015 RIN Number: N/A 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 enrolle d 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 continuin g to make pay ments on his or her loan. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. With the exception of th e in

- school deferment (see I tem 3), there is no information alread y 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 an y methods used to minimize burden. A small entit y 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 n ot

- 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 , count y, town, township, school district, or special district with a population of l ess than 50,000. No small businesses are affected b y this information collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y 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 quarter ly ;
 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;4

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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 y ears;
 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 b y OMB;

 that includes a pledge of confidentiality that is not supported by

authority established in statute or regulation, that is not supported by disclosure an d data security policies that are consistent with the pledge, or that unnecessaril y i mpedes 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 b y 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 b y 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

o f collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), 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 y ears

– 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 circumstance s should be explained. The Department considered comments from the public when developin g the currentl y approved form s. Furthermore, the Department will consider any comments provided during both the 60

- day

comment period and the 30

- day comment period. T his is the request for the 60 day

public comment period.
9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification

. No pay ments or gifts have been provided to r espondents.
10. Describe an y 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 a5

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- 00 11 Revised: 3/9 /2015 RIN Number: N/A citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated o n the I C Data Form . A confidentiality statement 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 statement is deemed sufficient with respect to confide ntiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. The forms include a Privacy Act Notice that (1) informs borrowers of the statutory authority for the informatio n 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 whi ch those disclosures may occur. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should inclu de the reasons wh y t he 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 an y steps to be taken to obtain their consent. The Tempora ry

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 t o establish the borrower’s eligibility for the deferment. The deferment forms do not otherwise request an y 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 ty

pe (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 t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agenci es should not conduct special survey s 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 widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual business practices.

2 Requests for this information are in accordance with the follow ing 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 Maint aining 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 Protec tion of Personally Identifiable Information)6

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 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 ROCI S IC Burden Analy sis 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, identify ing and using appropriate wage rate categorie s. The cost of contracting out or pay ing outside parties for information collection activities should not be included here. Instead, this cost should be included in I tem 14. The previous filing included mathematical errors in the total number of respond ents 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 PL WM 204 .16 32.64 33 PUB 12,558 .16 2009.28 2,009 TDI S 1,061 .16 169.76 170 UNEM 199,193 .16 3,312.64 31,871 PLUS 20,704 .16 3,312.64 3,313 TOTAL S 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 17

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**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: 335,66 6 **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: 3 3 **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: 1 70 **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: 3,31 38

O MB Number: 1845

- 00 11 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 e stimated reporting burden of 500,453 hours. There are no annual costs to respondents associated with operating or maintaining sy stems or purchasing services.
13. Provide an estimate of the total annual cost burden to respondents or record keepers result ing 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 lif e); 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 e stimate major cost factors including s ys tem 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, preparat ions 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 widel y, 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 respon dents (fewer than 10), utilize the 60

- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.

 Generally , estimates should no t 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, operational9

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- 00 11 Revised: 3/9 /2015 RIN Number: N/A 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 L oan, or Perkins L oan borrowers, since loan holders and servicers distribute and process the loan discharge application s, and ED servicers do not specificall y charge the government for distributing these forms

. 15. Explain the reasons for an y 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 materiall y 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 t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion) , ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (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 i nformation collected on these forms however, the forms h ave been simplified and reformatted to present a common lay out for these t ypes of requests. There has been no change in the underl ying 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 analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending d ates 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 inform ation 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 an y exceptions to the "Certification for Paperwork Reduction Act Submissions".