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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Reporting under Pell Grant Common Origination and Disbursement (COD) System

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify any

legal or administrative requirements that necessitate the collection. Attach a hard copy of the 

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

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

The Federal Pell Grant program is a student financial assistance program authorized 

under the Higher Education Act of 1965, as amended (HEA). The program provides

grant assistance to an eligible student attending an institution of higher education. The 

institution determines the student’s award and disburses program funds on behalf of the 

Department of Education (ED).

Institutions are required to report student Pell Grant payment information to ED 

electronically. Electronic reporting is conducted through the Common Origination and 

Disbursement (COD) system. The COD system is used by institutions to request, report, 

and reconcile grant funds received from the Pell Grant program. More information about 

the COD system is available on ED’s web site at http://ifap.ed.gov under the section 

“Systems & Processing Links – Programs”

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.

ED uses the information collected in the COD system to aid in ensuring compliance with 

fiscal and administrative requirements under the HEA for the Pell Grant program and 

under 34 CFR 690 for the Pell Grant program regulations.

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.

 

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Please limit pasted text to no longer than 3 paragraphs.
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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

COD is a multi-functional application providing options to participating institutions for 

processing Federal grant program data electronically. COD may be used as a high 

volume transaction application, or as a fully web-enabled application for which ED 

provides the necessary software (EDExpress) at no charge. Institutions are not required 

to use EDExpress – they may develop their own software, purchase software, or contract 

with a third-party servicer to report Pell Grant data to ED via the COD system.

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.

There is no information available from any other source that contains the information in 

this data collection.

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.

ED makes available, at no charge, software (EDExpress) that an institution may use to 

report Federal grant data in the XML format required under the COD system.

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.

Without this information, ED cannot process payments to institutions for students who 

are eligible to receive Pell Grant program funds.

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;

 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 
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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

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.

Institutions are required to report Federal grant data to ED more frequently than quarterly 

to account for the expenditure of Federal funds in a timely manner and to otherwise meet 

the program’s statutory and regulatory requirements.

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.

ED meets regularly with members of the financial aid community at national regional and 

state association conferences, as well as at the ED-sponsored conferences, on ways to 

improve the COD system. In addition to this 60 day comment period, there will be a 30

day comment period open for the public to provide input regarding these burden 

estimates.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

ED will not provide payment or gifts to users of the COD system. The submission of the 

Pell Grant data is mandatory.

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 
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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

No assurance of confidentiality is provided to respondents.

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

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

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

No questions of a sensitive nature are requested in COD.

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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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

The minimum reporting requirement is one record for origination and disbursement 

data per student, per grant award, per award year. Institutions may correct an 

accepted COD record as many times as they wish, but are not required to submit 

changes unless the student’s award amount changes from the accepted origination 

amount originally established in COD.

The current burden for this collection is:

Respondents Responses Burden Hours

 5,447 9,792,925 685,505

For the 2014-2015 award year, the projected number of FAFSA completers is 

expected to be reduced by 2.86%. Based on the 8,738,722 unduplicated student 

recipients for the Federal Pell Grant program for 2013-2014, the number of 

unduplicated Federal Pell Grant recipients for 2014-2015 is estimated to be 8,488,843

multiplied by .07 hours per recipient for the institution to enter data in the COD

system for a total of 594,219 hours. 

Affected Entities # of # of Hrs/ Burden

Respondents Responses Response Hours

For-profit institutions 2,116 1,697,769 .07 118,844

Not-for-profit institutions 1,717 1,103,549 .07 77,248

Public 1,879 5,687,525 .07 398,127

Revised Totals 5,712 8,488,843 594,219

We estimate the burden costs to the institutions to be $16 to $21 per hour. The 

average burden cost estimate for an institution is between $1,664 (104.03 hours X 

$16/hour) and $2,185 (104.03 hours X $21/hour). For the 5,712 institutions the total 

cost is between $9,507,510 and $12,478,606. The average total cost is estimated at 

$10,933,058.

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 
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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

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

equipment; and acquiring and maintaining record storage facilities.

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

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

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

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

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

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

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

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

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

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

usual business or private practices. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There are no additional costs to respondents other than those listed in Item #12.

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.

The annual cost to the Federal Government for the processing of this information is 

estimated to be $26,972,400. This cost includes ED labor costs, contractor staff time in 

preparing and electronically transmitting the information; contractor costs associated with 

processing the payment data submitted by institutions; and recording and analyzing the 

data for funding decisions and ensuring the institution’s compliance with the program 

statute and regulations.

ED labor and program administration costs = $2,948,400

Contractor costs for processing the student payment data = $24,024,000.

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, 
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OMB Number: 1845-0039 Revised: 03/17/2015

RIN Number: XXXX-XXXX (if applicable)

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

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

This is a request for an extension of the current collection package. There is a decrease in 

the burden hours of 91,286 due to the anticipated decrease in the number of eligible Pell 

Grant recipients. There is no change to the underlying regulations.

16. For collections of information whose results will be published, outline plans for tabulation 

and publication. Address any complex analytical techniques that will be used. Provide the time 

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

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

The results of the collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

ED is not seeking approval not to display the OMB expiration date.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

There are no exceptions to the certification statement.