EDICS Tracking & OMB Number: 1840-04910 Revised: 10/31/2012

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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 that necessitate the collection. Attach a hard copy of the 

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

information, or you may provide a valid URL link or paste the applicable 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 Education 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 determining 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 compliance 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 publication 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 Department) 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 the 
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Secretary of systemic non-compliance with the agency’s policies. Accrediting agencies 

whose 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 

purposes 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 describing 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 whom, and for what purpose the information is to be used. Except for a 

new collection, indicate the actual use the agency has made of the information received from 

the current collection.

The purpose and use of the information collection requirement for which 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 hours 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 what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms of 

information technology, e.g. permitting electronic submission of responses, and the basis for 

the decision of adopting this means of collection. Also describe any consideration given to 

using technology to reduce burden.

. 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 on the agency’s website, the agency can 

inform Department staff and provide the web address.
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4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2 

above.

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 the collection of information impacts small businesses or other small entities, describe 

any methods used to minimize burden. A small entity may be (1) a small business which is 

deemed to be one that is independently owned and operated and that is not dominant in its 

field of operation; (2) a small organization that is any not-for-profit enterprise that is 

independently owned and operated and is not dominant in its field; or (3) a small government 

jurisdiction, which is a government of a city, county, town, township, school district, or special 

district with a population of less than 50,000.

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 collection 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 cause an information collection to be conducted 

in a manner:

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

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

fewer than 30 days after receipt of it;

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

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;
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 in connection with a statistical survey, that is not designed to produce valid and reliable 

results than can be generalized to the universe of study;

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

approved by OMB;

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

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

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

agencies for compatible confidential use; or

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

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

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

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 Federal Register 

notices as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior 

to submission to OMB. Summarize public comments received in response to that notice and 

describe actions taken by the agency in response to these comments. Specifically address 

comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or 

reported.

Consultation with representatives of those from whom information is to be obtained or 

those who must compile records should occur at least once every 3 years – even if the 

collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.
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Under the Administrative Procedure 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 regulations 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 criteria 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. 

This provision of the previously 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 any 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. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide 

a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation 

that authorizes the pledge of confidentiality should be provided. 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 confidentially 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 

behavior and attitudes, religious beliefs, and other matters that are commonly considered 

private. The justification should include the reasons why the agency considers the questions 
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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 collection of information. The statement 

should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private sector –

not-for-profit institutions, farms, state, local or tribal governments), frequency of 

response, annual hour burden, and an explanation of how the burden was estimated, 

including identification of burden type: recordkeeping, reporting or third party disclosure. 

All narrative should be included in item 12. Unless directed to do so, agencies should not 

conduct special surveys to obtain information on which to base hour burden estimates. 

Consultation with a sample (fewer than 10) of potential respondents is desirable. If the 

hour burden on respondents is expected to vary widely because of differences in activity, 

size, or complexity, show the range of estimated hour burden, and explain the reasons for 

the variance. Generally, estimates should not include burden hours for customary and 

usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden Analysis 

Table. (The table should at minimum include Respondent types, IC activity, Respondent 

and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of 

information, identifying and using appropriate wage rate categories. The cost of 

contracting out or paying outside parties for information collection activities should not 

be included here. Instead, this cost should be included in Item 14.
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The number of accrediting agencies (not-for profit associations) that respond to the 

information collection is 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 regulations 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 credit hour review 

policies and procedures

36 agencies x 10 hours 360 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 based 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 accrediting 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. 
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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

Summary 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 

maintenance and purchase of services component. The estimates should take into 

account costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing equipment; 

and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing economic 

or regulatory impact analysis associated with the rulemaking containing the information 

collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions 

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and 
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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 information. 

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 disaggregated by type of change (i.e., adjustment, program change due to 

new statute, and/or program change due to agency discretion), type of collection (new, 

revision, extension, reinstatement with change, reinstatement without change) and include 

totals for changes in burden hours, responses and costs (if applicable).

The 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 compared 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 will be used. Provide the 

time schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

The department does not formally publish any of the information it collects from 

accrediting agencies. However Department staff does prepare an analysis of an 
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agency’s compliance with the criteria for recognition, based in part on the information 

that the agency submits in its application for recognition. That analysis 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 display 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 submit 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 information does not employ statistical methods.