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EDICS Tracking and 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 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.

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 Family Education Loan (FFEL) Program, 

the William D. Ford Federal Direct Loan (Direct Loan) Program, and the Federal Perkins 

(Perkins) Loan Program may temporarily defer payments on his or her eligible loans while 

serving on active duty during a war or other military operation or national emergency, and for an 

additional 180-day period following the conclusion of the borrower’s qualifying 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 Loan, 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 duty while enrolled at an eligible school or within six months of having been enrolled may

defer repayment 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. This deferment is known as a “post-active duty student 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 Loan 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.

The 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 

 

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EDICS Tracking and 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 consistent 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 duty 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 

decision 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 establish 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 copy 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 

currently provide the only practical means for a borrower to submit a military service deferment / 

post-active duty 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 third-party certification or supporting documentation.

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 similar information already available from other sources that can be used for the 

purposes described in Item 2.
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EDICS Tracking and 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 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.

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 frequently, as well as any 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 duty 

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 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;
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EDICS Tracking and 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 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.

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 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.

We considered recommendations from the financial aid community when developing the 

currently approved military deferment request form, and when drafting the revised form that 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 Loan Servicing Alliance (SLSA) 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 SLSA, and ED’s 

responses to those comments are included with this submission. In addition, the public will be 

consulted by way of an additional, 30-day comment period.

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

of contractors or grantees with meaningful justification.

No payments or gifts will be provided to respondents.
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EDICS Tracking and OMB Number: (1444.05) 1845-0080 Revised: 7/9/2013

RIN Number: N/A (if applicable)

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.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.

The deferment request form includes a Privacy Act Notice that (1) informs the respondent of the 

statutory authority 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 disclosures may occur.

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.

This information collection does not request any 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 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.

 

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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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EDICS Tracking and 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 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.

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 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 
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EDICS Tracking and 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 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

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, Direct Loan, and Perkins borrowers, since FFEL Program loan 

holders, Direct Loan servicers, and Perkins schools distribute the form, collect the information, 

and process the deferment requests.

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).

ED is not reporting any 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 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 this information collection will not be published.
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EDICS Tracking and 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. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The Department is not requesting any exceptions to the Certification for Paperwork Reduction 

Act Submissions of OMB Form 83-1.