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ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable)
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Student General Assistance Provisions**

**– Readmission for Servicemembers** 
**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 collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This is a request for an extension of the current information collection. As provided by the Higher Education Opportunity Act, the regul ations state the requirements under which an institution must readmit servicemembers with the same academic status they had at the institution when they last attended (or where accepted for attendance). The regulations require institutions to charge readmitted servic emembers, for the first academic year of their return, the same institutional charges they were charged for the academic year during which they left the institution (see section 484C of the HEA). The regulations are a result of regulatory review of the p rogram regulations to provide benefits to students, and protect the taxpay ers' interest. This request is for continued approval of recordkeeping requirements contained in the regulations related to the administrative requirements of the readmission requir ements for servicemembers program. The information collection requirements in the regulations are necessary to determine eligibility

to receive program benefits and to prevent fraud and abuse of program funds.
**General Provisions:** (OMB control number: 1845
- 0095 ) Section 668.18 contains information collections requirements. Under the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)), the Department of Education is submitting a copy of this section to the Office of Management (OMB) for its review. **Section 668.18 (c)**

**– Readmission procedures** 

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable) The regulations create d procedures effective August 14, 2008, that provide d for the readmission of a student who was required to leave an institution of higher education in order to fulfill a service requiremen t in the uniformed services. An institution is not allowed to den y readmission under prescribed conditions. **Section 668.18(g)**

**– Documentation**  The student who wishes readmission to an institution of higher education under this regulatory

section shall pr ovide documentation to the designated institution office(s) showing they

haven’t exceeded the allowed service limitations and are eligible for readmission. Examples of acceptable documentation are included in this regulatory section. 2. I ndicate how, b y 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. This is a recordkeeping requirement for the institutions. They must retain the evidence of eligibility for readmission under this regulation in their files to be reviewed as required by regulation. The returning servicemember will provide documentation to the institution’s designated office(s) for the institution to determine eligibility for readmission by

evidencing the time served and the continuing eligibility of the servicemember for readmission. 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 an y consideration given to using technology

to reduce burden. The examples of satisfactory documents are all paper documents provided to the servicemember at the completion of the tour of service that caused the enrollment separation. Institutions may convert the information to an electronic format for storage purposes but this is not a requirement. 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 I tem 2 above. There is no duplication of data as a result of the collection of this information. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y may be (1) a sma ll 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 i n its field; or (3) a small government jurisdiction,3

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable) 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 impacted b y this collection. 6. Describe th e 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. Recordkeeping requirements are imposed to assure accountability of p rogram participants for proper program administration and less frequent collection could impair accountability

of program participants. 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 records, 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 study ;  requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;  that includes a pledge of confidentiality that is not supported by

authority esta blished 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 respondent s 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 information collection requirements require no special circumstances
. 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. Sum marize public 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.4

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable) Consultation with repres entatives 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 pre clude consultation in a specific situation. These circumstances should be explained. This is the 3 0 day

comment period request. The 60 day comment period for this collection package to solicit comments on the current burden assigned to this regulation was published as Federal Register Notice, Vol. 77, page 58819, on September 24 , 2012
. No comments were received during that 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 ments or gifts will be provided to the respondents
. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy . If personall y 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. These requirements do not cover an y confidential information. 11. Provide additional justification for an y questions of a s ensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y t he 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. The Department is not requesting an y s ensitive data. 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, private sector

– businesses or other for

- profit, private

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 Individuals, OMB M

- 03
- 22

– OMB Guidance for Implementing the Privacy Prov isions 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)5

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable)

sector

– not - for

- profit institutions, far ms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be in cluded 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. Consultation 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 usua l 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 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 collections of information, identify ing and using appropriate wage rate categorie s. 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. We estimate th at 2,482 servicemembers will apply for readmission under this reg ulation
. We estimate that it will take each servicemember approximately 10 minutes to gather together the appropriate documentation to provide to the school. We estimate the time for schools to process the information provided will be approximately

30 mi nutes per individual servicemember. Affected Entities and Burden: Revised Burden Inventory

# of # of # of Hours Respondents Responses Burden I ndividuals 2, 482 2, 482 X .17 hours = 422 hours Institutions: Public 7 94 7 94 X .50 hours = 397 hours Private 745 745 X .50 hours = 373 hours Proprietary 943 943 X .50 hours = 4 72 hours Subtotal 2, 482 2,256 1 , 242 hours TOTAL 4, 964 4, 964 1, 664 hours Current Burden Inventory

# of # of # of Hours Respondents Responses Burden 4,512 4,512 1,513 hours6

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable) Difference in Current and Revised Burden

+452 +452 +151 **A nnual Cost of Burden to Respondents**  We estimate that the cos t to the institutional respondents will be:

# of Est. $ per Est. $ Respondents Response Burden Individuals 2,482 .45 = $1,117

# of Est. $ per Est. $ Respondents Response Burden Institutions: Public 794 X $24.61 X .50 hours = $9,770 Private 745 X $24.61 X .50 hours = $9,167 Proprietary 943 X $24.61 X .50 hours = $11,604 Subtotal 2,256 $30,541 TOTAL 4,964 $31,658
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 I tems 12 and 14.)

 The cost estimate should be split into two component s: (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, maintaini ng, and disclosing or providing the information. I nclude descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over whi ch 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 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 e stimate. 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 anal ys is associated with the rulem aking 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 ass ociated with the information collection, (3) for reasons other than to7

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable) 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 is no additional cost burdens associated with this collection 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 suppor t staff), and any

other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from I tems 12, 13, and 14 in a single table. There are no additional costs to the Federal government as a result of the regulation. 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 disaggregated 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 changes in burden hours , responses and cost s (if applicable)
. This request is to extend the current information collection. There has been no revision to the required recordkeeping of the specific readmission regulations. The changes to the burden hour estimates are a result of an increase in the expected number of servicemembers who would apply for readmission under this regulation. The increase in th e burden hours is treated as an adjustment. 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 the collection of information 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.8

ICRAS Tracking and OMB Number: ( 1459.04 ) 1845
- 0095 v2 Revised: 11 / 21 / 2012 RIN Number: XXXX

- XXXX (if applicable) The Department is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certific ation 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.