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EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable)
**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 collection. 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 collectio n (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. Sections 428(b)(1)(M) [20 U.S.C. 1078(b)(1)(M)], 455(f)(2) [20 U.S.C. 1087e(f)(2)], and 464(c)(2)(A) [20 U.S.C. 1087dd(c)(2)(A)] of the Higher Education Act of 1965, as amended, (the HEA) provide that a borrower under the Federal Famil y Education Loan (FFEL) Program, the William D. Ford F ederal Direct Loan (Direct Loan) Program, and the Federal Perkins (Perkins) Loan Program may temporaril y defer payments on his or her eligible loans while serving on active dut y during a war or other military operation or national emergency , and for an add itional 180 - day

period following the conclusion of the borrower’s qualify ing military service. This deferment is referred to as a “military service deferment.” Section 493D of the HEA [20 U.S.C. 1098f] provides that a FFEL, Direct L oan, or Perkins Loan program borrower who (1) is a member of the National Guard or other reserve component of the U.S. Armed Forces or a retired member of the U.S. Armed Forces and (2) is called or ordered to active dut y while enrolled at an eligible school or within six months of having been enrolled may defer repay

ment of his or her eligible loans for up to 13 months following the conclusion of the borrower’s active duty

military service, or until the borrower returns to enrolled student status, whichever occurs earlier. T his deferment is known as a “post - active dut y s tudent deferment.” The regulations that govern the military service deferment and the post - active duty student deferment are in 34 CFR 682.210(t) and (u) [for the FFEL Program], 34 CFR 685.204(e) and (f) [for the Direct Loan Program], and 34 CFR 674.34(h) and (i) [for the Perkins L oan Program]. These regulations require a borrower to request a deferment and to provide information to the loan holder establishing the borrower’s eligibility for the deferment. Th e U.S. Department of Education (ED) is requesting a revision of the collection currently approved under OMB No. 1845 - 0080. ED is making no major changes to the military deferment
1 Please limit pasted text to no longer than 3 paragraphs.2

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable) form; rather, it is proposing a number of linguistic changes to be more cons istent with other approved loan servicing forms. A justification for the data elements on the deferment request is included at the end of this supporting statement. 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 currently

approved deferment request serves as the means by which a borrower submits a request for a military

service deferment to his or her loan holder and provides the loan holder with the information needed to establish that the borrower meets the eligibility requirements for the deferment. The revised deferment request form will continue to be used for this purpose, and will also serve as the means by which a borrower requests a post - active duty student deferment, and by which ED identifies Direct Loan borrowers who qualify for the no accrual of interest benefit for active dut y service members. 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 de cision of adopting this means of collection. Also describe any consideration given to using technology

to reduce burden. The collection of information does not involve the use of technological processes such as electronic submissions. A borrower must e stablish his or her eligibility for the deferment either by obtaining a certification from a military official on the deferment request form, or by providing the loan holder with a cop y of the borrower’s military orders. Because of the requirement for a third - party certification or submission of additional documentation, most borrowers prefer to use the United States Postal Service or an alternative mail delivery service currentl y provide the only practical means for a borrower to submit a military service deferment / post - active dut y student deferment request. At the option of the loan holder or loan servicer, however, the form could be adapted for online use by mapping the data elements to a web form and provided for the scanning and uploading of the th ird - part y certification or supporting documentation. 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. There is no similar information alread y available from other sources that can be used for the purposes described in Item 2.3

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable)
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A sm all 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 not - for - profit enterprise that is independently owned and ope rated 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 less than 50,000. No small businesses are affected by 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. If a borrower did not complete either request, there would be no means by which the loan holder could determine the borrower’s eligibility for a military

service deferment or post - active dut y student deferment, or the borrower’s eligibility for the Direct Loan Program’s no accrual of interest benefit for active duty service members. 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 quarterl y;
 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;

 requiring respondents to retain record s, 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 stud y;
 requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;4

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable)
 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 unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidenti al information unless the agency can demonstrate that it has instituted procedures to protect the information ’ s confidentiality to the extent permitted by law. The collection of this information will be conducted in a manner that does not involve any of the guidelines in 5 CFR 1320.5(d)(2). 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 pu blic 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

of 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 preclud e consultation in a specific situation. These circumstances should be explained. We considered recommendations from the financial aid community when developing the currentl y approved military deferment request form, and when drafting the revised form tha t was posted for review during the initial 60 - day public comment period. During the 60 - day comment period we received 28 comments from the National Council of Higher Education Resources (NCHER) and one comment from the Student L oan Servicing Alliance (SLS A) in response to a notice published in the Federal Register. We have made a number of additional changes to the form based on these comments. The comments submitted by NCHER and SL SA, and ED’s responses to those comments are included with this submissio n. Inaddition, the public will be consulted by

way of an additional, 30 - day

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 men ts or gifts will be provided to respondents.5

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable) 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 a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on 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 confidentiality . 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 deferment request form includes a Privacy Act Notice that (1) informs the respondent of the statutory authorit y for the information collection; (2) explains that disclosure of the requested information is voluntary , but is required in order for the deferment request to be processed; and (3) identifies the third parties to whom the information may be disclosed, and explains the circumstances under which such disclos ures 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 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 an y steps to be taken to obtain their consent. This information collection does not request an y s ensitive 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, priv ate 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 o f burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to base hour burden estimates. Consultati on 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 Maintaining Records About Individ uals, 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)6

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable)

 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 collection s of information, identify ing and using appropriate wage rate categories. 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 total estimated annual reporting hour burden for this information collection is approximately 8,000 hours. The burden estimate was calculated as follows: Estimated annual number of respondents: 16,000 Number of responses per borrower: x 1 Hours per response: x 0.5 (30 minutes) Annual hour burden: 8,000 hours The total estimated cost burden for this collection is $7,360. This estimate was calculated by multiplying the estimated number of respondents by the current cost of postage required to return the deferment request form ($0.46). 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 s ys tem and technology acquisition, expected us eful 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; monitori ng, 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 cost7

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable) burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60 - day

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

impact anal ys is 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) pri or 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 busines s 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 are no 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, 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 significant cost to the federal government associated with military deferment requests submitted by

FFEL , Dir ect Loan, and Perkins borrowers, since FFELProgram loan holders, Direct Loan servicers, and Perkins schools distribute the form, collect the information, and process the deferment requests. 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 disaggreg ated 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 chan ges in burden hours , responses and cost s (if applicable) . ED is not reporting an y changes in the burden hour estimate. 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 dates of the collection of information, completion of report, publication dates, and other actions. The results of this information collection will not be published.8

EDICS Tracking a nd OMB Number: ( 1444.05 ) 1845 - 0080 Revised: 7/9/2013 RIN Number: N/A (if applicable)

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 is not seeking this approval. 18. Ex plain 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 of OMB Form 83 - 1.