EDICS Tracking & OMB Number: 1840

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1 **Supporting Statement For**  **Request for OMB Extension**
The Secretary’s Recognition of Accrediting Agencies
**A. Justification**  **1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements tha**  **t 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 section. 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 Secretary of Ed ucation is required to publish a list of nationally recognized accrediting agencies that the Secretary determines to be reliable authorities regarding the quality of education or training offered by the institutions or programs they accredit. In determinin g whether a specific agency should be recognized, the Secretary evaluates the agency for compliance with the Criteria for Recognition contained in regulations. The collection of information is necessary for the Secretary to evaluate the agency’s complianc e with each of the criteria and to monitor its continued compliance with the criteria during any period of recognition granted. The collection described below is being submitted due to changes in the 34 CRF Part 602 as a result of the Department’s publicat ion of a final rule and also to the approaching end of the 3 year approval period

. The authority for collecting this information is contained in the Higher Education Act of 1965, as amended (HEAs ), and 34 CRF Part 602. The Department of Education (the Depa rtment) is requesting OMB review and approval of the following paperwork sections in the regulations under OMB Control Number 1840

-0788. This submission is a revision of a currently approved collection. (a) Information accrediting agencies must submit to ED § 602.24(f) describes an agency’s responsibilities for reviewing an institution’s assignment of credit hours, for taking actions on deficiencies, and for notifying theEDICS Tracking & OMB Number: 1840

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2 Secretary of systemic non

- compliance with the agency’s policies. Accrediting age ncies whos e accreditation can enable an institution to be eligible to seek and to participate in title IV, HEA programs (36 of the 61 agencies) are expected to assess institutions to determine if they have made credit hour determinations for title IV, HEA program pu rposes that meet at least the minimum standards in the definition of a credit hour in 600.2, in light of commonly accepted practices in higher education. In determining compliance with this regulation, the Department reviews the agency’s narrative describ ing how it complies with the criteria, and supporting documentation (such as its credit hour policies and procedures, guidance it provides to institutions, an institution ’s self

- study, and the agency’s report of its onsite review). **2. Indicate how, by who m, 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 purpose and use of the information collection requirement for whic h the Department is requesting OMB approval are discussed below. 602.24(f) requires the accrediting agency to review an institution’s policies and procedures for assigning credit hours and to make a determination that they result in assignment of credit ho urs that conform to commonly accepted practice in higher education. The information is required to ensure a degree of consistency in the assignment of credit hours, which are the basis upon which Title IV funds are allotted. **3. Describe whether, and to w hat 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 deci sion of adopting this means of collection. Also describe any consideration given to**  **using technology to reduce burden.**

. The Department has implemented a web

- based, electronic information collection system that allows agencies to submit their applications for recognition and compliance reports electronically. The system allows agencies to attach supporting documents for a petition or report in electronic format as well. If some of the material an agency needs to submit with its application is available o n the agency’s website, the agency can inform Department staff and provide the web address.EDICS Tracking & OMB Number: 1840

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3 **4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes d**  **escribed in Item 2 above.**  The information collected is not obtained through any other means within the Federal government. The information on agencies is collected only through the accrediting agency recognition process the Department administers. **5. If t he 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 domin**  **ant 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.**  Collection of this information does not involve small businesses or other small entities. **6. Describe the consequences to Federal program or policy activities if the col lection is not**  **conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.**  Not collecting the information or collecting the information less frequently would jeopardize the recognition process by not allowing the Secretary to obtain the information needed to determine an accrediting agency’s compliance with 34 CFR Part 602, subpart B. The requirement to review accrediting agencies every 5 years is statutory. **7. Explain any special circumstances that would ca use 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 r** **eceipt of it;**

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

 **requiring respondents to retain records, other than health, medical, government contract, grant** **- in** 
**- aid, or tax records for more than three years;** EDICS Tracking & OMB Number: 1840

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4  **in connect ion 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 oth**  **er agencies for compatible confidential use; or** 

 **requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to**  **protect the information’s confidentiality to the extent permitted by law.**  There are no special circumstances that would cause an information collection to be conducted in a manner consistent with any of examples listed above.
**8. As applicable, state that the Department has published the 60 and 30 Fe**  **deral 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 thes**  **e 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 keep**  **ing, 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.** EDICS Tracking & OMB Number: 1840

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5 Under the Administrative Procedu re Act (APA) (5 U.S.C. 553), the Department is generally required to publish a notice of proposed rulemaking and provide the public with an opportunity to comment on proposed regulations prior to establishing a final rule. In addition, all Department regu lations for programs authorized under the title IV, HEA programs are subject to the negotiated rulemaking requirements of section 492 of the HEA. Public comment is solicited through the notice of proposed rulemaking. The data collection consists of the cr iteria for recognition (regulations) that result from a negotiated rulemaking process. The process takes place on an irregular basis following a change in the governing statute or decision by Department leadership to engage in negotiations. Th is provisio n of the previous ly approved collection proposal was not included for public comment in a 60/30

- day Federal Register Notice submitted in October 2009. This data collection solicited public comments through 60/30

- day Federal Register Notices. **9. Explain an y decision to provide any payment or gift to respondents, other than**  **remuneration of contractors or grantees with meaningful justification.** The Department does not provide any payment or gift to an accrediting agency that applies for recognition.
**10. Descr ibe 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 instru**  **ment. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was**  **completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should**  **be provided. If 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 confid entially of the data.**  No assurances of confidentiality are given to the accrediting agencies other than those provided under the Freedom of Information Act. **11. Provide additional justification for any questions of a sensitive nature, such as sexual behavi**  **or and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency considers the questions** EDICS Tracking & OMB Number: 1840

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6 **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.**  There are no questions of a sensitive or private nature in the information to be

collected.

**12. Provide estimates of the hour burden of the co llection 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 inclu**  **ded 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 re**  **spondents 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 b**  **usiness practices.**

 **If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCIS IC Burden Analysis**  **Table. (The table should at minimum include Respondent types, IC activity, Respondent**  **and Responses, Hours/Response, and Total Hours)**

 **Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of**  **contracting o ut or paying outside parties for information collection activities should not**  **be included here. Instead, this cost should be included in Item 14.**EDICS Tracking & OMB Number: 1840

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7 The number of accrediting agencies (not

-for profit associations) that respond to the information collection i s 61

. However, this provision applies only to 36 of this group [the institutional accrediting agencies that are recognized for Title IV purposes ]

. **The estimate of the additional burden on accrediting agencies to collect information for the new section of**  **the regulation**  **s is as follows:**  Burden for requiring agencies to report to the Department on their compliance with the credit hour regulations

36 agencies x 2 hours 72 hours Burden for requiring institutional accrediting agencies to establish new cred it hour review policies and procedures

36 agencies x 10 hours 36 0 hours **The rationale used in determining the burden:**

The estimate of the burden on agencies to develop credit hour policies and procedures is based upon information provided by a small sample of accrediting agencies and then applied to all accrediting agencies. The Department believes this estimate is reasonable. The estimate of the burden on agencies to report to the Department on their compliance with the credit hour regulation was ba sed upon the additional time needed to describe in its petition for recognition (or renewal of recognition) its policies and procedures and to upload relevant documentation. This is a standard part of the application process ; agencies are already required to respond to a large number of criteria. The estimate is based upon information provided by a small sample of accrediting agencies and then applied to all accrediting agencies. The Department believes this estimate is reasonable

. **The estimated costs to a ccrediting agencies and institutions:**  To estimate the cost to accrediting agencies, the Department used wage information from the Bureau of Labor Statistics. The March 2012 total private education and health services average hourly earnings of $24.07 was used as the hourly rate to monetize the burden of these provisions.EDICS Tracking & OMB Number: 1840

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8 The estimate of the additional cost for agencies to collect information for this new section of the regulation is as follows: §602.24(f).............................. ....................Staff Salaries: $ 10,398.24 **Su mmary for the current and proposed burden:**  Current approved burden: 4453 hours Proposed burden increase: 432 hours **13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.**  **(Do not include the cost of any hour burden shown in Items 12 and 14.)** 

 **The cost estimate should be split into two components: (a) a total capital and start**
**- up cost**  **component (annualized over its expected useful life); and (b) a total operation and maintena**  **nce 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 syste**  **m 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 pu**  **rchasing 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 re** **asons 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 servic es, 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** EDICS Tracking & OMB Number: 1840

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9 **usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12** 
**.** There is no cost to any agency for collecting the information required to be submitted to the Department on an annual basis because all of the information is being collected in conjunction with the existing data collection effort. **14. Provide estimates of annualized cost to the Federal government. Also, provide a description**  **of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any**  **other expense that would not have been incurred without this collection of informat ion.**  **Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.** There is no direct cost to the Federal government to collect the information agencies must submit. **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 disaggreg** **ated 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 chan**  **ges in burden hours, responses and costs (if applicable).** The new regulation expands reporting requirements outlined in the current regulations that have led to an increase in burden. The overall impact has led to a 432 hour increase in the burden when co mpared to the current burden of 4453 hours. There is no increase in number of respondents. **16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that wi**  **ll 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 department does not formally publish any of the informatio n it collects from accrediting agencies. However Department staff does prepare an analysis of anEDICS Tracking & OMB Number: 1840

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10 agency’s compliance with the criteria for recognition, based in part on the information that the agency submits in its application for recognition. That anal ysis is presented to the National Advisory Committee on Institutional Quality and Integrity when that body meets to review the agency’s application . That analysis is available to the public electronically via the web. **17. If seeking approval to not displa y the expiration date for OMB approval of the information**  **collection, explain the reasons that display would be inappropriate.** The department seeks approval not to display the expiration date for OMB approval of the information collection because the Department does not use a form to collect the information. The Office of Postsecondary Education/Accreditation division currently displays and will continue to display the OMB Control Number for this collection on the website used by accrediting agencies to su bmit recognition petitions. **18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.**  No exception is requested.
**B. Collections of Information Employing Statistical Methods**  The collection of info rmation does not employ statistical methods.